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Law Offices of •
COQ "1TY 1650 38TH STREET
Bartley A. Costello, JR., P.C. SUITE 201 WEST
A PROFESSIONAL CORPORATION BOULDER, COLORADO 80301-2637
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TELEPHONE: (303)442-7200 INTERNET: http://www.injurylaw.<om/auto
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(303)4a4�3304 !L. +� E-MAIL: infoeinjurylaw.com
July 2, 1996
REGISTERED MAD., RETURN RECEIPT REQUESTED,to the following:
Attorney General
Ms. Gail Norton
1525 Sherman, 5th Floor
Denver, CO 80203
Weld County Commissioners
915 10th Street
Greeley, CO 80631
RE: My Client- Raemona Howard
Date of Injury: April 18, 1996
Governmental Entity: Weld County, State of Colorado
Location of Collision: WCR 36 and WCR 3,Weld County, Colorado
Tort Notice Pursuant to C.R.S. 24-10-109
Dear Sirs & Madams:
Since the exact governmental organizations are not known at this time,this Notice of Tort Claim
is being provided to the above referenced parties. Please forward this notice to the appropriate parties.
I have been retained to represent Raemona Howard in all matters stemming from injuries she
received in the above referenced collision. I am writing to provide Notice of Claim pursuant to C.B.S.
24-10-109.
A. Claimant:
Raemona Howard, 18463 WCR 3, Berthoud, CO 80513. I am the attorney for Ms. Howard and
my name and address appears at the top of this letterhead.
B. Basis of Claim:
On April 18, 1996,at approximately 17:05 p.m., a collision occurred on Weld County Road 36 at
its intersection with Weld County Road 3,in the County of Weld,State of Colorado. Attached is a copy
of the Traffic Accident Report which is herein fully incorporated by reference. On that date, Ms.
Howard's car was traveling South on Weld County Road 3. At that time Jeff Williams was operating
a vehicle Westbound on Weld County Road 36. At the aforementioned time and place,Ms.Howard was
y� proceeding through the intersection. Mr. Williams failed to yield the right of way and Ms. Howard
1►i \ l) 961269
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Tort Notice
July 2, 1996
Page 2 of 2
struck the side of Mr. Williams's vehicle. To Claimant's best knowledge, Claimant will assert that the
appropriate governmental entities,and/or their contractors,agents,servants,employees,were negligent
regarding failure to warn of a dangerous and uncontrolled intersection,the dangerous condition of the
roadway, and negligent design of the roadway and intersection, and negligent design and maintenance
of the roadway and intersection, and failure to place a traffic control devise in this intersection.
C. Public Employees:
It is not known to Claimant at this time exactly which public employees may be involved.
D. Nature and Extent of Injury:
The exact nature and extent of the injury is not fully realized. However, Ms. Howard suffered
temporary,total and permanent partial disabilities to her body,past and future pain and suffering,loss
of enjoyment of life, impairment of earning capacity, lost wages, medical, hospital, other health-care
expenses, and property damage.
E. Amount of Danm es:
The exact amount of monetary damages is unknown at this time. However, Claimant expects that
Ms. Howard's claim will not exceed $200,000.00. At this time, Claimant therefore states the damages
to be $200,000.00.
Sincerely,
Bartley A. Costello,Jr.
BAC:dmw
Enclosure: Colorado Traffic Accident Report
cc: Raemona Howard
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ri U14"Ists_ti°•Veh #1 (Williams) was westbound on WCR 36. Veh #2 (Howard)
I was southbound on WCR 3. Veh #2 struck veh #1 right broadside on the
l side. Both vehicles rotated clockwise, and ran oft the southwest corner
of the intersection. Veh #1 rolled 1 time, ejecting the driver. Both
vehicles came to rest on their wheels.
. Diagram on Back O 1
RECEWFD
JUN 1 8 1996
0033
1 1 2 1 4 1 1 00000 same As Driver #1
2 1 1 2 3 1 1 00000 _ Same As Driver #2 J
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