HomeMy WebLinkAbout20120904.tiff DUARDO J,HRSZT
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March21,2012 ESN" ED
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Board of County Commissioners. . , . John B.Cooke
Weld County Weld County Sheriff
1150"O"St. 1950"O"St.
Greeley,CO 80632 Greeley,CO 80632
RE: Governmental Immunity Notice Letter
My client: Francisco Carrillo
SENT CERTIFIED MAIL; RETURN RECEIPT REQUESTED
To Whom It May Concern:
Please be advised,pursuant to C.R.S. 14-10-109,that this office represents Mr. Francisco Carrillo on any and all
claims he may have a right to claim. Mr.Francisco Carrillo slipped and fell at the County Jail while working,
mopping floors in the capacity of a trustee. The Claimant is Francisco Carrillo,and he resides at 168 N. 10th Ave.,
Brighton,CO 80601. Mr.Carrillo is represented by Eduardo Ferszt,Esq.,3025 South Parker Road,Suite 711,
Aurora,CO 80014.
The employees known to the claimants are agents and employees of the Weld County Sheriff's Office who were
charged with the oversight and provision of work supplies to the trustees and to Mr.Carrillo in particular. They
also include any individuals charged with providing medical care and attention to Mr.Carrillo.These
employees/agents include,but are not limited to: Deputy Ryan Allen Barash;Cyndi(LNU) RN, H.S.A.; Margo
Geppert, MD;Maria Gerlach,MA; Nancy Kroll, Director Inmate Services.
On November 21, 2011,Mr.Carrillo was tasked with the duty of mopping floors inside the Weld County Detention
Facility and slipped and fell on the very floor that he was mopping. Our contention of liability is that Mr.Carrillo
was provided with shoes/foot coverings that had no sort of traction or grip and which county officials could or
reasonably should have foreseen as being a danger to anybody wearing the same who would be treading over any
wet or slick areas.
Because of the negligent ads and/or omissions of the Weld County Jail agents, my client suffered significant
medical damages and spinal disc injury and had to hire counsel to represent him to enable him to obtain redress
for the damages suffered. County officials have made no attempt whatsoever to assume any responsibility for the
medical treatment rendered and still needed to resolve the orthopedic injuries suffered by Mr.Carrillo.
We intend to bring suit for the following actions and any other causes of action which can be determined as
discovery continues: gross negligence and negligent supervision.
Claimant respectfully demands$500,000.00 in full and final satisfaction of all claims herein.
Please contact my office to discuss the particulars of this demand.
Sincerely,
Eduardo""Ferszt
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THE MARKET PLACE • 3O25 SOUTH PARKER ROAD • TOWER II, SUITE 4'TOt7• AURORA, CO 8OO14
TELEPHONE: 3O3-696-9155 • FAcstMILe:303-745-7286• E-MAIL: EDFERSZT@YAHOO.COM
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