HomeMy WebLinkAbout20051982.tiff Coleman, Liu, Lyons,
-& Collins L.L.P
C/L
LC
Colorado's Trial Law Firm
June 28, 2005
Clerk to the Board
Board of County Commissioners
915 10th Street
P.O. Box 758
Greeley, CO 80631
NOTICE OF CLAIM
Re: Suit by Harold Andrews
Dear Clerk to the Board and County Commissioners:
The purpose of this letter is to serve notice, pursuant to Colorado Revised Statutes, § 24-
10-109, of the intent of Harold Andrews, a resident of Weld County Colorado, whose address is
2110 O Street, Greeley, Colorado, to file suit against Weld County for negligence on the part of
employees of the Weld County Sheriff's Department resulting in physical injury.
Mr. Andrew's suit stems from events that took place on or about April 11, 2005 at 9:30
p.m. at the Weld County Jail in the T-F Pod, 2110 O Street, Greeley, Colorado, where Mr.
Andrews was being held in custody. While standing in line for medication distributed by an
employee of the Weld County Sheriff's Department, Mr. Andrews was assaulted by fellow
inmate Alan Meads. Alan Meads lunged over the medicine cart and struck Mr. Andrews one
time in the nose with a closed right fist. Mr. Andrews is an adverse witness in a homicide case
currently pending against Alan Meads. This assault was witnesses by at least two employees of
the Weld County Sheriffs Department. Pursuant to its own policy, the Weld County Sheriff's
Department placed a"Keep Separate" order in effect between Mr. Andrews and Alan Meads.
This order mandates that Mr. Andrews and Alan Meads have no contact while both are housed at
the Weld County Jail.
As a result of being struck in the nose by Alan Meads, Mr. Andrews suffered a fractured
nose bone, a fractured left nasal passage, and a fractured left orbital bone. On April 24, 2005,
Mr. Andrews underwent surgery to repair his broken nose. At this time, Mr. Andrews is waiting
to see if he will be required to undergo further surgery in an attempt to fully repair the damage
done to his nasal passage and orbital bone.
812 8th Street•Greeley,Colorado 80631•(970)336-6499•Fax(970)353-0214
72,4 Keith C.Coleman •Maria Liu•Shannon Lyons•Christopher G. Collins • Robert A.Wiest
m.0774,AN e^ J'Ya,"1/5 (04-j) 2005-1982
As a result of striking Mr. Andrews, Alan Meads was charged intimidating a witness
C.R.S. § 18-9-704 and second-degree assault C.R.S. § 18-3-203. Mr. Andrew's physical
injuries, physical pain, and mental and emotional pain and suffering are a result of negligence on
the part of employees of the Weld County Sheriff's Department. The Weld County Sheriff has
failed to adequately train his employees in the Weld County Jail. Additionally, employees of the
Weld County Sheriff's Department failed to properly supervise inmates under their charge
housed in the jail. Finally, employees of the Weld County Sheriff's Department failed to comply
with their own mandate to keep Alan Meads separate from Mr. Andrews. Mr. Andrews believes
the Weld County Sheriff's failure to adequately train his employees in the jail, failure to
adequately supervise inmates in the jail, and failure to keep Alan Meads separate from him
resulted in his injuries.
Although exact monetary damages are not yet know, Mr. Andrews will seek an amount
of damages no less than fifty thousand Dollars ($50,000.00).
Mr. Andrews has retained Coleman, Liu, Lyons & Collins, L.L.P, to represent him in this
matter and therefore all correspondence or inquiries should be directed to undersigned counsel.
Sincerely,
Coleman,Liu Lyons & Colli s, L.L.P
Robert A. Wiest
812 8th St. Plaza
Greeley, CO 80631
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