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HomeMy WebLinkAbout950944.tiffDENVER OFFICE 303 E. 7TH AVE. SUITE 700 DENVER. COLORADO 80203 13031 5601886 °Il 2: 28 CLERK C) THE 80:..nn HAND DELIVERED WIS. GRAY, SCHUETZE & GORDON ATTORNEYS AT LAW THE EXETER BUILDING SUITE 501 1050 WALNUT STREET BOULDER, COLORADO 60302-5144 TELEPHONE 13031442-3366 FAX 13031 440-3688 April 19, 1995 The Board of County Commissioners of the County of Weld c/o Bruce Barker, County Attorney Weld County Attorneys Office 915 10th Street P.O. Box 1948 Greeley, Colorado 80632 Re: Notice Pursuant to C.R.S. §24-10-109 PLEASE REPLY TO BOULDER OFFICE To The Board of County Commissioners of the County of Weld: This constitutes notice pursuant to C.R.S. §24-10-109. 1. The names of the claimants are: Roberta Henrickson and Gary Henrickson whose address is 13278 Weld County Road 32, Platteville, Colorado 80651. 2. The names and addresses of the attorneys for the claimants are: John A. Purvis and Robert A. Schuetze, PURVIS, GRAY, SCHUETZE & GORDON, 1050 Walnut Street, Suite 501, Boulder, Colorado 80302. 3. On October 31, 1994, at the intersection of County Road 32 and railroad tracks east of Highway 85, in the Town of Platteville, County of Weld, Colorado, a vehicle driven by Claimant Roberta Henrickson was struck by the locomotive of a train operated by the Union Pacific Railroad. The condition of that railroad crossing and of the roadway and public right-of-way approaching that crossing constituted a dangerous condition under C.R.S. §24- 10-103 and C.R.S. §24-10-106, inter alia. 4. The names and addresses of the public employees involved are not presently known. 950944 p,); cA cam) The Board of County Commissioners of the County of Weld April 19, 1995 Page 2 5. The nature and extent of the injuries claimed to have been suffered are, without limitation: (a) Serious brain, musculoskeletal, internal, and psychological injuries to Claimant Roberta Henrickson, physical and mental pain, suffering, and distress, loss of life enjoyment, hospitalization and therapy care and expense, loss of earning capacity, all past and future. (b) Loss of rights of consortium of Claimant Gary Henrickson arising from the injuries to his wife, Claimant Roberta Henrickson. 6. The amount of monetary damages being requested by each claimant is the full amount as permitted by statute under C.R.S. §24-10-114. 7. This notice is given within one hundred eighty days after the date of discovery of the above -described injuries. PURVIS, GRAY, SCHUETZE & GORDON By n A. Purvis bert A. Schuetze Hello