HomeMy WebLinkAbout20082696.tiff 09-26-'08 11:35 FROM- T-401 P002/007 F-254
September 24, 2008
Weld County Commissioners
Mr. William Jerke, Chair
Mr. David Long
Mr. Douglas Rademacher
Mr. Rob Masden
Mr. Bill Garcia
915 10th St.
Greeley, Colorado 80632
Bruce Barker, Esq.
Weld County Attorney's Office
915 10th St.
Greeley, Colorado 80632
NOTICE OF CLAIM •
This is to put you on notice of a potential claim against Weld County as required by
C.R.S. § 24-10-109.
A. Name and Address of Claimant's Attorney
Name and address of Claimant:
Ms. Carol Bliss
3200 E. 168th Ave.
Brighton, CO 80601
Names and addresses of attorney:
Brent M. Martin
Martin & Martin,P.C.
303 E. 17`h Ave., Ste. 1070
Denver, CO 80203 •
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2008-2696
09-26-' 08 11:36 FROM- T-401 Pa03/007 F-254
Notice of Claim
Weld County Commissioners
Weld County Attorney's Office
September 24,2008
Page Two
B. Statement of the Factual Basis of the Claim
On Wednesday April 2, 2008 at approximately 5:00 pm the claimant was in the process
of entering the Weld County Courthouse located at 901 9`h Avenue in Greeley, Colorado, 80631.
As claimant was standing on the second floor landing waiting to clear security, she was asked to
step back by a security guard, upon stepping back she fell down all the stairs coming to rest on
the landing of the first floor. This fall was caused by the negligent design, construction and or
maintenance of the security station at the Weld County Courthouse which was approved by the
governing body of Weld County and created a dangerous condition. Officials of Weld County
had actual knowledge of the dangerous condition prior to claimants fall. This fall caused the
claimant significant and permanent injuries as set forth more fully below.
C. Name and Address of Public Employee Involved if Known
At the time, neither the claimants nor their attorneys know the name(s) or address(es) of
the public employee or employees who were involved.
D. A Concise Statement of the Nature and Extent of the Damage Claim
The full nature and extent of injuries and damages suffered by claimant may not be fully
known at this time. However, her injuries and damages known at this time, include, but are not
limited to:
1. Compound fracture of left wrist (requiring surgical intervention to set);
2. Compound fracture of left humerus (requiring surgical intervention to set);
3. Medical Expenses;
4. Rehabilitation Expenses;
5. Pain and Suffering;
6. Emotional Distress;
7. Loss of Wages; and
8. Loss of enjoyment of life.
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07-LO- uo 11:60 rnun- i I flf2/V.O r a L.Jz
Notice Of Claim
Weld County Commissioners
Weld County Attorney's Office
September 24, 2008
Page Three
MONETARY DAMAGES CLAIMED
Claimant has suffered and requests damages in excess of$150,000.00.
Respectfully Submitted,
MARTIN &MARTIN, P.C.
Brent M. Martin
Certificate of Hand Delivery
I HEREBY CERTIFY that on this 26th day of September, 2008, mailed by certified and
registered mail a true and correct copy of the foregoing Notice of Claim to the following:
Weld County Commissioners
Mr. William .lerke, Chair
Mr. David Long •
Mr. Douglas Rademacher
Mr. Rob Masden
Mr. Bill Garcia
915 10th St.
Greeley, Colorado 80632
Bruce Barker, Esq.
Weld County Attorney's Office
915 10th St.
Greeley, Colorado 80632
Tel Trevino, Attorney
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