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Home My WebLink About20111612.tiff Amy E. Gaiennie Julia D. Schuster Laurence M. Schneider Cheryl Hixenbaugh Meredith A. Quinlivan Case Managers Attorneys at Law LAW ONCE Brenda Gallardo Heather McIntosh Karla C. Maldonado Legal Assistants June 28, 2011 Colorado Department of Transportation Headquarters Office 4201 E Arkansas Ave Denver CO 80222 Weld County 915 19`h Street Greeley, Colorado 80631 City of Greeley 919 7th Street, Suite 102 Greeley, Colorado 80631 Attorney General— State of Colorado 1525 Sherman Street, 7th Floor Denver, Colorado 80203 RE: Date of Loss: 12/31/2010 Our Client: Mohamed Faray Our Client 4: A123110-960 Dear Sir or Madam: Please let this be your notice of claim under C.R.S. § 24-10-109. The Gaiennie Law Office represents Mr. Faray regarding injuries and damages sustained in a motor vehicle accident on December 31, 2010. Please take notice of the following: A. On behalf of: Mohamed Faray P.O. Box 461172 Glendale, Colorado 80247 Represented By: The Gaiennie Law Offices, LLC Meredith A. Quinlivan, Esq. Amy E. Gaiennie, Esq. 3801 E. Florida Avenue, Suite 310 Denver, Colorado 80210 Cz crvinwt ,o Ra e e • (5 Loriq� u, 1 6Z 3801 East Florida Avenue Suite 310 Denver, CO 80210 Phone: (303) 455-5030 Fax: (303) 455-0805 E-mail: amy@amyglaw.com B. On December 31, 2010 at approximately 12:30pm Mr. Faray was operating his 2001 Isuzu Rodeo northbound on Colorado Hwy 85. At the intersection of Weld County Road 6 Mr. Faray lost control of his vehicle due severe weather conditions. Mr. Faray collided with a traffic light pole and sustained severe bodily injuries. C. Unknown D. As a result of CDOT, the City of Greeley, Weld County and the State of Colorado's failure to properly remove snow and ice from the roadway, Mr. Faray was unable to stop his vehicle and caused him to lose control. Mr. Faray was hospitalized for four months in a coma, suffered a traumatic brain injury and injuries to his neck, back and extremities which has left him permanently disabled. E. Based on the foregoing, I have evaluated this claim in excess of$250,000.00. Therefore, Mr. Faray demands the payment of monetary damages as a result of injures suffered in the automobile accident. Sincerely, In 7 't / ,7 Meredith A. Quinlivan' / Amy E. Gaiennie e � Julia D. Schuster Laurence M. Schneider Cheryl Hixenbaugh Meredith A. Quinlivan Case Managers Attorneys at Law LAW OFFECE Brenda Gallardo Heather McIntosh Karla C. Maldonado Legal Assistants June 28, 2011 Colorado Department of Transportation Headquarters Office 4201 E Arkansas Ave Denver CO 80222 Weld County 915 19th Street Greeley, Colorado 80631 City of Greeley 919 7th Street, Suite 102 Greeley, Colorado 80631 Attorney General— State of Colorado 1525 Sherman Street, 7th Floor Denver, Colorado 80203 RE: Date of Loss: 12/31/2010 Our Client: Mohamed Faray Our Client #: A123110-960 Dear Sir or Madam: As you are aware, we represent Mohamed Faray for injuries suffered in an incident on December 31, 2010. By this letter, you and your insured are hereby given notice not to destroy, conceal or alter any paper or electronic files and other data generated by and/or stored on your insured's computers and storage media (e.g. hard disks, floppy disks, backup tapes), any other electronic data, such as voice mail or electronic data recorders (black box), or security video tape recording or still photos or film from cameras of the scene of the incident. Moreover, you and your insured are hereby given notice not to destroy, conceal or alter any paper or electronic files of your insured's drivers' logs, cabin logs, maintenance logs, your insured's drivers' employment file and Drivers' Qualification File. As you know, your insured's failure to comply with this notice can result in severe sanctions being imposed by the Court for spoliation of evidence or potential evidence. 3801 East Florida Avenue Suite 310 Denver, CO 80210 Phone: (303) 455-5030 Fax: (303) 455-0805 E-mail: amy@amyglaw.com Your insured is also to preserve and not destroy all passwords, decryption procedures, network access codes, ID names, manuals, tutorials, written instructions, decompression or reconstruction software, and any and all other information and things necessary to access, view and (if necessary) reconstruct data. Sincerely, / i j Meredith A. Quinlivan Hello