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living in San Leandro she has experienced an incredible loss of independence and must rely <br />on others because of the barriers she encounters to and from her home. <br />6. Specific instances and locations at which Ms. Leffmann has encountered barriers in <br />the City's PROW during the period of time extending back six (6) months prior to the filing <br />of this claim, and a description of those barriers are as follows: <br />a. On September 9, 2025 and on many occasions prior to and after that date, Ms. <br />Leffmann encountered a portion of the sidewalk in front of 1506 139th Avenue <br />that was inaccessible and caused her difficulty because a section of the concrete <br />sidewalk is cratered, cracked, crumbled, deteriorating, uneven and angled to the <br />right and uplifted, causing a change in elevation greater than one-half inch. <br />b. On September 9, 2025 and on many occasions prior to and after that date, Ms. <br />Leffmann encountered a portion of the sidewalk at 139th Avenue and Bancroft <br />Avenue (in front of 13902 Bancroft Avenue) that was inaccessible and caused <br />her difficulty in traveling through that area because of a utility pole which <br />causes the width of the sidewalk to be narrower than three feet. <br />c. On September 9, 2025 and on many occasions prior to and after that date, Ms. <br />Leffinann encountered a portion of the sidewalk at the corner of 140th Avenue <br />and Bancroft Avenue (near 1517 140th Avenue) that was inaccessible and <br />caused her difficulty in traveling through that area because of a utility pole <br />which causes the width of the sidewalk to be narrower than three feet. <br />d. On September 9, 2025 and on many occasions prior to and after that date, Ms. <br />Leffmann encountered a portion of the sidewalk on Bancroft Avenue between <br />139th Avenue and 140th Avenue (across the street from the church) that was <br />inaccessible and caused her difficulty and discomfort because a section of the <br />concrete sidewalk is cracked and has landscaping encroaching into the PROW <br />and a van that is parking in the driveway which intersects the PROW so that it <br />impassable for a person in a wheelchair or other mobility device. <br />