The family of Desiree McCloud, who died in 2016 after crashing her bike on a track of the First Hill Streetcar, and a rider who survived her crash a year later at the same E Yesler trackway are joining forces to sue the City of Seattle.

“The Defendant City knew there were other bicycle crashes occurring when bike tire were caught in streetcar rail grooves before DESIREE’s injuries and death and SUZANNE GREENBERG’s injuries,” the lawsuit filed just before Christmas reads.

Suzanne Greenberg was injured when she crashed her bike near the spot at 13th and Yesler where McCloud had fallen a year after the deadly incident.

McCloud, 27, died following her May 2016 crash that led to calls for safety improvements near Seattle’s streetcar tracks. The city’s investigation was unable to determine if the First Hill Streetcar tracks had caused the fatal crash.

Their joint lawsuit reads like a project list any street, bicycling, and pedestrian planner would be familiar with in Seattle.

Lawyers from the firm Campiche Arnold contend that the city neglected to include a laundry list of street safety measures in the area of the crash including the lack of a separated bikeway on Yesler:

The Broadway Bikeway, derided by many for its lack of bike traffic, runs parallel to Broadway’s portion of the First Hill Streetcar route and provides riders with a way to travel the artery without negotiating the tracks. Opened in January 2016 as part of a transportation mitigation plan after Sound Transit cut its planned First Hill light rail station, SDOT’s First Hill Streetcar runs 2.5 miles between Pioneer Square and Capitol Hill. With ridership below expectations and pushback from the business community concerned about the construction and loss of parking, plans to extend the route north on Broadway — and the Broadway bikeway along with it — have been axed.

In the suit, the plaintiffs say they will seek financial damages to be determined. If the case proceeds, the trial is scheduled for December of 2018.