In the Matter of the Claim of Jose Antonio Munoz, by and through __________

as Guardian at Litem and the City of Los Angeles

APPLICATION FOR LEAVE TO PRESENT LATE CLAIM

[Gov. Code 911.4]

TO CITY OF LOS ANGELES:

Application is hereby made for leave to present a late claim under Section 911.4 of the
Government Code. The claim is founded on a cause of action for personal injuries, which accrued on
October 23, 2012, and for which a claim was not timely presented.

For additional circumstances relating to the cause of action, reference is made to the proposed
claim attached hereto as Exhibit A and made a part hereof.

The reason for the delay in presenting this claim is the mistake and/or inadvertence and/or
surprise and/or excusable neglect of the claimant and his attorney, H. Douglas Daniel, as is more
particularly shown in the declaration of H. Douglas Daniel attached hereto as Exhibit B. Moreover, the
claimant was a minor during all of the period when the claim should have been presented, as shown by
the declaration of H. Douglas Daniel.

The City of Los Angeles was not prejudiced in the defense of the claim by the failure to file the
claim in a timely manner, as shown by the declaration of H. Douglas Daniel.

This application is presented within a reasonable time after the accrual of the cause of action
and does not exceed one year from the date of accrual of the cause of action

WHEREFORE, it is respectfully requested that this application be granted and that the attached
claim be received and acted on in accordance with Sections 912.4912.8 of the Government Code.

Dated:________________ _______________________________________

H. Douglas Daniel

Attorney for Claimant

 Exhibit A

CLAIM FOR DAMAGES

TO: CITY OF LOS ANGELES

Jose Antonio Munoz, by and through __________ as Guardian at Litem, hereby makes claim
against the City of Los Angeles for a sum in excess of $25,000 and makes the following statements in
support of the claim:

1. Claimants post office address is 7060 Park Manor Avenue, Los Angeles CA 91608, California.

2. Notices concerning the claim should be sent to: H. Douglas Daniel, 611 Wilshire Blvd, Suite 1204 Los
Angeles CA.

3. The date and place of the occurrence or transaction giving rise to this claim are: October 23, 2012 at
the corner of Wheatland Avenue and Rainier Street in Los Angeles, CA.

4. The circumstances giving rise to this claim are as follows: the intersection of Wheatland Avenue and
Rainier Street in Los Angeles was in a dangerous condition due to ________________________
_______________________________________ and, because of the dangerous condition, plaintiff was
struck by a vehicle as he rode his bicycle.

5. Claimants injuries are strain and sprain injuries to his back and neck and abrasions.

6. The names of the public employees causing the claimants injuries are unknown at this time.

7. My claim as of the date of this claim is $. This figure is based on the following:

Medical Expenses Incurred to Date: $

Estimated Future Medical Expenses: $

General Damages: $

TOTAL $
8. The claim as of the date of this claim is in an amount that would place it within the jurisdiction of the
superior court. The claim is based on damages alleged above in an amount to be proved later.

9. All notices related to this claim should be sent to H. Douglas Daniel, 611 Wilshire Blvd,. Suite 1204,
Los Angeles, CA 90012.

Dated: October ____ 2013 ________________________________________

H. DOUGLAS DANIEL
On Behalf of Claimant
 Exhibit B

DECLARATION OF H. DOUGLAS DANIEL IN SUPORT OF APPLICATION FOR LATE CLAIM

H. DOUGLAS DANIEL, ESQ., declares as follows:

1. The following is within my personal knowledge and if called upon to testify, I could and
would competently testify thereto.

2. I am an attorney duly licensed to practice before all courts in the State of California and
am the attorney of record for claimant in the above-entitled matter.

3. I was retained by claimant on _______________ to represent him in this matter. I

learned that the traffic incident that gave rise to claimants injuries occurred on October 23, 2012. I
understood that I had six months in which to file a government claim with the City of Los Angeles as I
believed the City was at least partially responsible for claimants injuries due to the dangerous condition
of public property that existed at the location where the accident to occurred.

4. I did not file the tort claim within the six month statutory period because ____________.
My failure to file the tort claim was, however, the product of inadvertence, mistake and excusable
neglect. Moreover, I do not believe that the City will be prejudiced by allowing claimants claim to go
forward.

I declare under the penalty or perjury that the foregoing is true and correct and if asked to
testify I could and would testify competently thereto. Executed this _____ of October 2013 in Los
Angeles, California

_____________________________

H. DOUGLAS DANIEL, Esq.

Attorney for Claimant