Casarotti, through his attorney Joseph A. Androvich of the Sacramento firm Poswall White & Brelsford, claims in a February 2018 complaint that the roadway was in a "defective and dangerous condition," and that "there is simply not enough room for a bicycle and car to share the road and safely negotiate the curves with out colliding with one another."
Old La Honda Road is likely a town-owned road, Androvich said. The complaint names the county and Caltrans as defendants, he said, because it's "almost impossible" to determine what agency controls a road without putting in a claim against them.
Both Caltrans and Ofer Doitel, the driver of the truck, responded to the complaint with detailed answers, court records show.
Doitel, represented by Jerome P. Bellotti of the San Jose firm Hartsuyker, Stratman & Williams-Abregci, claims that Casarotti freely accepted the risks of the activity; that he was negligent and careless; and that other defendants were the proximate cause of losses, damages, injuries and harm.
Caltrans' defense, by four agency attorneys, included that Casarotti was negligent, that he appreciated and voluntarily assumed the risks, and that Caltrans is immune from liability.
John Beiers, chief counsel for San Mateo County, said the accident location seems outside the county's jurisdiction and that his office is working with Androvich to get dismissed from the case.
Kevin Bryant, Woodside's town manager, cited the town's practice of not commenting on pending litigation.
The crux of the case is simple, Androvich said."There are very low-cost preventive measures that can ... prevent this type of accident," he said. "If the town had been proactive in trying to create a safe path of travel ... Claudio wouldn't have been injured."
One low-cost measure: laser beams placed ahead of curves that, when broken by the passage of a vehicle, flash warning lights to vehicles approaching the curves from the other side.
Once a triathlete
The complaint claims Casarotti's medical bills are about $100,000, with injuries that include a broken neck, a broken nose, disfiguring facial lacerations, a fractured clavicle and arthritis in his neck and clavicle. Casarotti is a marathoner and was a triathlete, Androvich said, but the clavicle injury has left him unable to swim.
Casarotti is seeking remedies that include general damages (commonly called pain and suffering), and payment for medical expenses, loss of earnings and attorney fees.
Asked if Casarotti was familiar with the road, Androvich said he was, enough to know the best line and speed through a curve.
The area where the accident happened "constituted a trap to the unwary," the complaint says, noting the absence of warnings regarding the possibility of oncoming traffic. As a result, cyclists use the road "as is," but even with due care, they face a "substantial risk" of injury, the complaint says.
About 90 feet from the intersection with Skyline Boulevard, Old La Honda Road does have a yellow "Narrow Winding Road" warning sign.
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