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Brice A. Tondre, P.C.
215 South Wadsworth Boulevard,Suite 500
Lakewood,Colorado 80226
(303)296-3300
FAX:(303)238-5310
E-mail:briceatondrepc@msn.com
November 12, 2008
Sheriff John B. Cooke CERTIFIED MAIL
Weld County Sheriff RETURN RECEIPT REQUESTED
1950 "O" Street
Greeley, CO 80631
Bruce Thomas Barker, Esq.
Weld County Attorney
915 Tenth Street
P.O. Box 758
Greeley, CO 80632
Board of County Commissioners of Weld County
915 Tenth Street
P.O. Box 758
Greeley, CO 80632
NOTICE OF CLAIM PURSUANT TO COLORADO
GOVERNMENTAL IMMUNITY ACT
C.R.S. §24-10-109
Claim is hereby made pursuant to C.R.S. §24-10-109 for injuries
sustained by Jenna Velder while in custody of the Weld County Sheriff's
Department.
I. Name and address of claimant:
Jenna Velder
42985 County Road V
Acron, CO 80720
970-345-6494
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II. Name and address of claimant's attorney:
Brice A. Tondre
215 South Wadsworth Boulevard
Suite 500
Lakewood, CO 80226
303-296-3300
303-238-5310) (fax)
III. Statement of basis for claim:
Jenna Velder, DOB 7/25/70, SS# 524-90-8137, was booked
into and released from the Weld County Jail on May 16, 2008. When she
entered the jail both of her feet were bandaged due to severe burns and she
was on a prescribed regimen of therapeutic substances. She was booked in at
9:08 a.m. and boo}+ced out at 12:08 p.m.
During the: three hours she was in the jail a person purporting to have
the authority to ilk so, removed the bandages from her feet in an non-sterile
atmosphere and treated her feet in a non-sterile fashion despite Ms. Velder's
protestations tlt,at said conduct was placing her at risk for infection.
(
The afor}ementioned treatment was done in a fashion which
deliberately, wlillfully and wantonly disregarded Ms. Velder's serious
medical need . Ms. Velder was denied use of the prescribed regimen of
therapeutics bstances which she brought with her.
On I ay 20, 2008, Ms. Velder was hospitalized in the intensive care
unit of the burn clinic at University Hospital for an infection of her feet
caused by he non-sterile treatment and the refusal to allow her the use of the
prescribed t erapeutic regimen.
IV. ame and address of public employee involved:
The na e of the public employee involved is presently unknown.
V. St tement of nature and extent of injury:
Infectior i of both feet resulting in hospitalization, lost
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time from her job, pain, suffering and emotional distress.
VI. Amount of monetary damages:
The cost of hospitalization, loss of wages and non-economic damage
aggregating at least $500,000.00.
Very truly yours,
Brice A. Tondre
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