Cline

I. BACKGROUND

1 On July 15, 2017, Mr. Cline and his mother were living in their white Dodge pickup with a 2 camper shell and parked at Felton Covered Bridge Park. Decl. of Jonathan Gettleman (“Gettleman 3 Decl.”), Ex. M, Rumrill Incident Report 18, 20, ECF 69-3. Ms. Kathryn Cline was 87 years old at 4 the time. Id. 16. 5 Earlier that day, while walking to the public bathroom in the park, Ms. Cline fell, landing 6 on her hip and hitting her head. Decl. of Elizabeth M. Caballero (“Caballero Decl.”), Ex. C, 7 Rumrill Dep. 62:6-10, ECF 61-1; Ex. N, Cline RFA 231, ECF 61-1. Mr. Cline reported to the 8 officers that, in the process of falling, she re-injured a pre-existing head wound. Ex. C, Rumrill 9 Dep. 62:1-13, ECF 61-1. Mr. Cline picked her up, carried her to the car, and went across the street 10 to a Valero gas station to get ice for her leg. Caballero Decl., Ex. F, David Cline Dep. 106:4-13, 11 ECF 61-1. Mr. Cline testified that he tried to convince his mother to go to the hospital, but, 12 according to him, she wanted to wait and see how she felt after the ice and said about her hip, “it 13 doesn’t hurt that much.” Id. 106:4-22. Bystanders who were familiar with the Clines…