HomeMy WebLinkAbout950945.tiff.. ._JD CO ii 4IS, GRAY, SCHUETZE & GORDON
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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
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: Gary L. Hamilton and
Brittany K. Hamilton, surviving spouse and daughter, respectively,
of Kathleen M. Hamilton, deceased. The address of claimants is
3750 W. 24th Street, #101, Greeley, Colorado 80634.
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 25, 1994, at the intersection of County Road
38 and railroad tracks immediately east of Highway 85, north of the
Town of Platteville, County of Weld, Colorado, a vehicle driven by
Claimant Gary L. Hamilton was struck by the locomotive of a train
operated by the Union Pacific Railroad. Kathleen M. Hamilton,
deceased, was a passenger in that vehicle and incurred fatal
injuries in that collision. 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.
950945
The Board of County Commissioners
of the County of Weld
April 20, 1995
Page 2
5. The nature and extent of the injuries claimed to have
been suffered are, without limitation:
(a) The wrongful death of Kathleen M. Hamilton, the
spouse of Claimant Gary L. Hamilton and mother of
Claimant Brittany K. Hamilton, a minor, and all
damages and losses resulting therefrom.
(b) Severe injuries to Claimant Gary Hamilton
including, without limitation, permanent paraplegia
of the lower body, physical and mental pain,
suffering, and distress, loss of life enjoyment,
extensive hospitalization and therapy, and
attendant care and expense, loss of earnings and
loss of earning capacity, all past and future.
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
C -
n A. Purvis
obert A. Schuetze
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