HomeMy WebLinkAbout931648.tiff B'R E G A & WINTERS P. C. ATTORNEYS AT LAW
November 16, 1993
l":'ID COE TY
Pamela A. Shaddock VIA REGISTERED MAIL
Director
352-4805 CLE ;
Weld County Commissioners TO IT I- r n
P.O. Box 758
915 10th Street
Greeley, Colorado 80632
GREELEY Bruce Barker, Esq.
Bradley D.Lau.
Pamela A.Shaddock Weld County Attorney
Jerty D.Winters P.O. Box 1948
DENVER 915 10th Street
Mark J.Appleton Greeley, Colorado 80632
James W.Bain
Thomas D.Birge
Charles r.Brega
Robert R.Dormer State Attorney General
Wesley B.Howard
State Services Building
Edc R Jonsen en
Robert C.Kaufman 1525 Sherman Street
Ronald S.LoserDenver,
A.Magoon Colorado 80202
Loren L.Mall
Cathryn B.Mayers
Carla B.Minckley Dear Sir or Madam:
Jay John Schnell
Nathan D.Simmons
Scott L.Terrell' This letter is written pursuant to § 24-10-109, C.R.S. and the
'Member of the Patent Bar purpose of this letter is to give notice of the following claim which my
client may have against you as a public entity.
One Norwest Center
1700 Lincoln Street
Suite 2222 A. The name of the claimant and the name and address of er
Denver,CO 80203 attorney is:
Mk(303)861-9109
(303)866-9400
Claimant:
Alice M. Leonard
Attorney:
Pamela A. Shaddock, Esq.
Brega & Winters P.C.
1100 10th Street,.#402
Greeley, Colorado 80631
-
931648
nt.; ISo�i yo) PE
V United Plaza • 1100'tenth Street, duke 402 • P.O. Box 127 • Greeley, Colorado 8O632 • FAX: (303) 352.6547 • (303) 352.4005
1 i/aa l93
B' R RE GA A & WINTERS P. C. ATTORNEYS AT LAW
•
November 16, 1993
Page 2
B. A precise statement of the factual basis of the claim, including the
date, time, place, and circumstances of the act, omission, or event complained of:
On the 21st day of August, 1993 at approximately 12:20 p.m., the
claimant, Ms. Alice Leonard, was driving her 1986 Chevy Blazer automobile in
an easterly direction on Weld County Road 74. A 1978 Dodge Aspen automobile
was being driven by David G. Kindvall in a northerly direction on Weld County
Road 47. Mr. Kindvall pulled up to the stop sign at the intersection of these two
roads. He then proceeded into the intersection and he alleges that a tall growth of
weeds impaired his vision so that as he entered the intersection from the South, he
could not see clearly. The Kindvall vehicle then pulled into the path of the
Leonard vehicle, causing damage to the claimant. The claimant had the right-of-
way. The tall growth of weeds was along a roadway right-of-way which would
have been the responsibility of the Weld County Road Maintenance Department
to maintain. Under the statute, the tall growth of weeds would be a dangerous
condition along a public highway, road or street. It is unknown at this time
whether the State of Colorado had any obligation for maintenance.
C. The name and address of any public employee involved:
Any names are unknown at this time. However, claimant believes
that agents of Weld County, in particular the Weld County Road Maintenance
Department, would have had responsibility for maintenance of this roadway right-
of-way.
D. A concise statement of the nature and extent of the injury claimed to
have been suffered: -
As a result of this collision, at a minimum, claimant suffered a
fractured right ankle; four fractured ribs; a sore and swollen left wrist; a lacerated
bottom lip which had to be reconstructed; extensive dental work, as well as pain
and suffering. The permanent effect of these damages is still unknown. In
addition, claimant has suffered loss of enjoyment of life with regard to these
injuries.
BREGA & WINTERS P. C. ATTORNEYS AT LAW
November 16, 1993
Page 3
E. A statement of the amount of monetary damages that is being
requested:
The full amount of my damages is, as yet, undetermined; however,
I would ask the maximum allowed at law.
Yours very truly,
BREGA & WINTERS P.C.
(914Set—C
Pamela A. Shaddock
Attorney At Law
PAS/jae
cc: Mrs. Mice M. Leonard
1O564001\weldcty.001 _
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