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Home My WebLink About20060997.tiff March 21, 2006 Bruce Barker, Esq. SENT VIA REGISTERED MAIL Weld County Attorney P.O. Box 758 Greeley, CO 80632 Weld County Commissioners SENT VIA REGISTERED MAIL 915 Tenth Street P.O. Box 758 Greeley, CO 80632 Nick Meier SENT VIA REGISTERED MAIL Manager, Town of Platteville 400 Grand Avenue Platteville, CO 80651 Carmen Beery SENT VIA REGISTERED MAIL Town Attorney for Platteville 2401 15th St. Ste 200 Denver, Co 80202 Thomas E. Norton —Executive Director SENT VIA REGISTERED MAIL Colorado Department of Transportation 4201E. Arkansas Avenue Denver, CO 80222 John W. Suthers—Attorney General SENT VIA REGISTERED MAIL State of Colorado —Attorney General's Office 1525 Sherman Street, 5th floor Denver, CO 80203 ARTHUR AND EDITH KIRCHNER, NEXT OF KIN OF DECEDENT JOLIE KIRCHNER, BY AND THROUGH UNDERSIGNED COUNSEL, HEREBY GIVE NOTICE OF CLAIMS AGAINST A GOVERNMENTAL ENTITY PURSUANT TO C.R.S. §24-10-109 Uo MmUAUC 778AJS �� `. C e S lX 2006-0997 To Whom It May Concern: Pursuant to C.R.S. §24-10-109, please take notice that Jolie Kirchner was killed, and her next of kin including Edith and Arthur Kirchner, her parents, and Terry Kirchner, her sister and nieces and nephew, Kathleen, Kelsey, and Michael, have sustained damages and losses, all due to the negligence of one or more of the above named governmental entities on September 25, 2005. CLAIMANTS: Edith and Arthur Kirchner, decedent's parents 1104 Mulberry Cheyenne, WY 82001 Teresa Kirchner, decedent's sister; and nieces and nephew, Kathleen, Kelsie and Michael Gley 5031 Windmill Cheyenne WY 82009 CLAIMANTS' ATTORNEY: James E. Fitzgerald 2108 Warren Avenue Cheyenne, WY 82001 FACTUAL BASIS OF CLAIM: DATE: SEPTEMBER 25, 2005 TIME: 05:00 A.M. PLACE: Highway 66, at Milepost 49, at or near County Road 21, near Platteville, Colorado. CIRCUMSTANCES OF THE EVENT COMPLAINED OF: At approximately 0500 on September 21, 2005, the decedent, Jolie Kirchner, was a passenger in a vehicle, a tractor-trailer going eastbound on Colorado State Highway 66. At or near the junction with County Road 21, and near milepost 49, the vehicle came upon cattle in the roadway. That caused the vehicle to go off the left side of the roadway and roll, coming to rest on its left side. Jolie Kirchner was killed. The Town of Platteville had sent personnel to the area earlier, before this wreck, to remove the cattle, but the cattle returned to the scene because they were not properly corralled or contained. Furthermore, the county and/or state failed to properly maintain, repair or otherwise deal with the fencing in the area so as to keep cattle off the highway. These governmental agencies were negligent. THE NAME AND ADDRESS OF ANY PUBLIC EMPLOYEE INVOLVED: The exact names of governmental personnel or their agents/servants are unknown. However, the responsible governmental entitities have been notified hereby, pursuant to C.R.S. §24-10-109. CONCISE STATEMENT OF THE NATURE AND THE EXTENT OF THE INJURY SUFFERED: As a direct and proximate result of the negligence stated above, Jolie Kirchner was killed and her survivors sustained economic and non-economic injuries, damages and losses. AMOUNT OF MONETARY DAMAGES THAT IS BEING REQUESTED: As a direct and proximate result of the aforementioned matter, the survivors sustained damages in the amount of$1,000,000.00. They request compensation for this crash-related death in the amount of$1,000,000.00. Dated March 21, 2006. James E. Fitz .er A108 Warren Ave e , Cheyenne, WY 82001 CERTIFICATE OF MAILING I, the undersigned, does hereby certify that the foregoing NOTICE pursuant to Colorado Revised Statutes § 24-10-109 was duly served by sending a true and correct copy of the same in the United States Mail, Registered, pursuant to United Postal Service procedures on March 21, 2005, addressed to: Bruce Barker, Esq. Weld County Attorney P.O. Box 758 Greeley, CO 80632 Weld County Commissioners 915 Tenth Street P.O. Box 758 Greeley, CO 80632 Nick Meier Manager, Town of Platteville 400 Grand Avenue Platteville, CO 80651 Carmen Beery Town Attorney for Platteville 2401 15th St. Ste 200 Denver, Co 80202 Thomas E. Norton—Executive Director Colorado Department of Transportation 4201 E. Arkansas Avenue Denver, CO 80222 John W. Suthers—Attorney General State of Colorado—Attorney General's Office 1525 Sherman Street, 5th floor Denver, CO 80203 /James E. Pit g$rald Hello