This action involved a tragic wrongful death accident wherein Defendant, MTA’s
employee, Defendant, Bus Driver negligently made a right turn and ran over decedent,
while she was walking within the cross-walk, on a “walk” sign, at the intersection of First
Street and Broadway in the City of Los Angeles.

Prior to the incident, decedent’s employer had dropped off decedent at the
intersection of First Street and Broadway, Los Angeles, California. Decedent’s employer
testified that he witnessed decedent enter the cross-walk on a “walk” sign. He further
testified that while he was proceeding southbound on Broadway, he noticed the subject
MTA Bus driver traveling at a high rate of speed northbound on Broadway. Defendant, bus
driver, made a statement to the reporting officer that while making his right turn he did not
notice any pedestrian’s within the cross-walk. However, Defendant bus driver admitted
in deposition that he felt a bump while making his turn and immediately stopped;
upon exiting the bus he noticed decedent pinned underneath the bus’ front right tire
with her body within the crosswalk. Following the incident, although, Defendant, bus
driver, attempted to move the bus, decedent remained pinned underneath the bus until the
paramedics arrived at which point she had died.

Decedent was a 53 year old single mother at the time of her death, and was not
only a loving mother and grandmother, but a hard worker. Decedent would work at
Gourmet facility during the graveyard shift, from 10:30 p.m. until the next day anywhere
from 6:00 a.m. to 10:00 a.m. After finishing her work decedent would come home to take
care of her grandchildren so that her daughter/Plaintiff could go to work and school.
Additionally, decedent took care of her own elderly parents. The only opportunity decedent
had to rest was on the weekends.

During the spare time that decedent had, she would spend it with her daughter and
grandchildren. They went to church together every Sunday. They also enjoyed watching
movies together and going out for lunch with the family. In addition to going to church on
Sundays, decedent helped the church with its special functions and activities.

Despite being a single mother decedent had saved from years of hard work and had
been able to purchase a triplex which she occupied with her daughter as well as her
grandchildren. Decedent and her daughter shared the responsibility of managing the
triplex. Decedent also financially supported her family. Decedent would not only pay for
the living expenses of her grandchildren and daughter, she also paid the home mortgage
and her daughter’s car payments. Decedent was a kind person always willing to help
another person. Following the purchase of her triplex, decedent even helped support her
sister’s step-daughter and daughter while she was pregnant by allowing them live with her.

As a result of the subject incident, decedent’s family sustained a great loss.