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BACHUS & SCHANKER LLC
J. KYLE BACHUS' 1400 160 STREET,SUITE 450
DARIN L. SCHANKER
ATTORNEYS AT ,P.
COUNTY V DENVER,CO 80202
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t1 qJ PHONE: 303.893.9800
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SHARI R. L.WILLIS?
MARC P. HARDEN
ANGELA E. MCGRAW9 2010 WC( 25 A q= liiI N.COLLEGE AVENUE,SUITE 211
FORT COLLINS,CO 80524
JAMES W. OLSENs PHONE: 970.493.4969
JEFFREY F. DEAN3d.s 2
ERIC M. PIZZUTI° U
May 17, 2010 3 ° `"""6 v C 'Also admitted in Florida
J. CHRISTOPHER ELLIOTT'' 'Also od in in Minnesota
Kesota
'Also admitted i in brask
'Also admitted Nebraska
'Also admitted dd in New York
'Also Washington
in Ohio
=Also admitted in Washington D.C.
VIA REGISTERED MAIL-RETURN RECEIPT REQUESTED 'Also admitted in Wisconsin
'Also admitted in Wyoming
Governor Bill Ritter John Suthers, Esq.
136 State Capitol Colorado Attorney General
Denver, CO 80203 1525 Sherman Street, Seventh Floor
Denver, CO 80203
Joan Henneberry, Executive Director
Colorado Dept. of Health Care Policy&Financing
1570 Grant Street
Denver, CO 80203
Douglas Rademacher, Chairman Bruce Barker,Esq.
Weld County Board of Commissioners Weld County Attorney
P.O. Box 758 P.O.Box 758
Greeley, CO 80632 Greeley, CO 80632
Judy Griego, Director
Weld County Department of Human Services
315 North 11th Avenue
Greeley, CO 80631
Re: Governmental Immunity Act Notice
My Client: Rick Kass
Date of Incident: January20, 2010
To Whom It May Concern:
This Notice of Claim is submitted pursuant to the Governmental Immunity Statute,
C.R.S. § 24-10-109.
1) The name and address of claimants and their attorneys:
Claimant: Rick Kass
8109 Mummy Range Drive
Fort Collins, CO 80528
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5- ac-iu
www.coloradolaw.net 2010-1196
Governmental Immunity Act Notice
Rick Kass
May 5,2010
Page 2 of 2
Attorneys: Jeffrey Dean,Esq.
BACHUS &SCHANKER, L.L.C
123 North College Avenue, Suite 211
Fort Collins, CO 80526
2) A concise statement of the factual basis of the claim including the date, time,
place and circumstances of the act, omission, or event complained of:
On or about January 20, 2010, upon information and belief, Rick Kass was
making a delivery to the Sunrise Community Health Center Dental Clinic located at
1006 A Street, Greeley CO 80631. He slipped and fell on ice that accumulated from
melting snow that had thawed and refrozen on the sidewalk. Mr. Kass was injured
as a result of the negligence of the responsible parties for failing to remove the ice
and for mounding snow which melted and formed ice on the side walk and poor
drainage for property of the city, and entities receiving funding from the county and
state.
3) The name and address of any public employees involved:
At this time, Claimant Rick Kass is not aware of the name of any specific
public employees involved.
4) Concise statement of the nature and extent of the injuries claimed to have
been suffered:
As a result of the above-referenced incident, Mr. Kass sustained personal
injuries, losses, and damages including, but not limited to, a fractured right leg. Mr.
Kass has incurred medical treatment as a result of his injuries and has sustained other
economic and non-economic damages and losses including, but not limited to,
medical bills, mental and physical pain and suffering, inconvenience, emotional
stress, disability, disfigurement, and impairment of quality of life.
5) A statement of the amount of monetary damages that is being requested:
At this time, claimant Rick Kass is requesting payment of no less than
$150,000.00.
Please contact me if you have any questions.
Sincerely,
BA M ii &SCHANKER, LLC
Jeffrey D-.n,Esq.
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