HomeMy WebLinkAbout20001483.tiff The Law Office of
_ Esteban A. Salazar, P.C.
1439 Fifth Street 970 356.1019
Greeley,CO. 80631 Fax.:970.356.1295
June 7, 2000
To: Weld County, Colorado
CIO: Board of County Commissioners
Weld County, Colorado
915 10"' Street
Greeley, CO 80631
and
Bruce Barker, Reg. No. 13690
County Attorney
915 10'h Street
Greeley, CO 80631
RE: Claims of Andre Kimboko and Priscilla Kimboko arising out of a collision with an
ambulance from the Weld County Ambulance Service which occurred on Colorado
Highway 34 at 8t Avenue on December 15, 1999.
Andre Kimboko AND Priscilla Kimboko GIVE NOTICE TO WELD COUNTY,
COLORADO AND ITS EMPLOYEES AS FOLLOWS:
IDENTITY OF CLAIMANTS:
The Claimants are Andre Kimboko and Priscilla ICimboko, husband and wife, who reside at
2736 W. 22°" Street, Greeley, CO 80631.
CLAIMANT ATTORNEYS:
Claimants Andre Kimboko and Priscilla Kimboko are represented by The Law Office of
Esteban A. Salazar, P.C., 1439 5th Street, Greeley, CO 80631.
BASIS OF CLAIM:
Claimants claims against Weld County, Colorado, and the County's employees are based
upon a motor vehicle collision that occurred on December 15, 1999, at 8"Avenue on Colorado
Highway 34 in Weld County, Colorado. The collision occurred at approximately 9:00 a.m..
Claimants sustained injuries, damages and losses as a result of Claimants' car being struck by
( ' a Q H21 0- , 00. 2000-1483
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June 7, 2000
a Weld County Ambulance. The collision resulted because of acts and failures to act on the part of
the County ambulance driver. The collision occurred when the County Ambulance driver proceeded
through a red light without adequate warning or reasonable care and struck the vehicle occupied by
Claimant Andre Kimboko. Improper training of the ambulance driver and improper maintenance of
the Ambulance may have contributed to the cause of the collision.
NAMES OF PUBLIC EMPLOYEES:
The involved operator of the Weld County Ambulance was Eric J. Simonds, 15741 HWY
392,Greeley,CO 80631. The names of other public employees such as Mr. Simonds' supervisor and
the persons who inspected and maintained the Ambulance, are presently unknown.
NATURE AND EXTENT OF INJURY AND DAMAGE:
The full nature and extend of injuries and damages suffered by Claimants are not fully known
at this time, but such injuries and damages include, but are not limited to:
Injuries Sustained by Andre Kimboko
•Fractured Hip;
• Ambulance/EMT expenses;
• Medical, surgical, doctor, hospital and rehabilitation expenses;
• Loss of earning capacity;
• Permanent disability;
• Disfigurement;
• Loss of enjoyment of life:
Injuries Sustained by Priscilla Kimboko
• Loss of consortium as a result of injuries to her husband Andres Kimboko.
Property damages Sustained by Andre or and Priscilla.
•Andre and Priscilla were joint owners of the 1999 Plymouth,Neon involved in the collision.
The claimants' automobile was damaged beyond economic repair. The value of the claimant's car
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June 7, 2000
before the collision was $12,000. The claimants also suffered a loss of use of their vehicle before it
could be replaced.
The claimants have also sustained losses incident to towing and storage of their damaged
vehicle.
MONETARY DAMAGES CLAIMED:
The full extent of monetary damages has not yet been fully ascertained. It appears that
damages will probably exceed $150,000.00 for Andre Kimboko and $100,000.00 for Priscilla
Kimboko.
Respectfully s
The L of
Estebfkr,5alaz. P.
stems . ar, 19954
1 F. e
Greeley, 0 80631'
(970) 351019
RETURN OF SERVICE
STATE OF COLORADO }
} ss
[CITY AND ] COUNTY OF WELD }
I declare under oath that I served this Notification Pursuant to Colo Rev Stat § 24-10-109
by personally serving it on the Board of County Commissioners of Weld County, Colorado, at 910
10th Street,Greeley,CO 80631 and Bruce Barker,Reg.No. 13690,County Attorney,91010'"Street,
Greeley, CO 80631 on at
I further certify that I am over the age of 18 and not interested in nor a party to this case.
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June 7, 2000
Private Process Server
Signed under oath before me on this
Notary Public
My commission expires:
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