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MARK SISUN & ASSOCIATES P.C.
Steven P. Hemmerle Attorneys at Law Accident and
Mark A. Sisun 90 Madison Plaza• Suite 302 Injury Law
Denver, Colorado 80206
(303)377-8861 FAX(303)377-0418
August 27, 1998
CERTIFIED - RETURN RECEIPT REQUESTED
County Attorney, Weld County
P.O. Box 948
915 10th Street
Greeley, CO 80632
Board of County Commissioners, Weld County
P.O. Box 758
915 10th Street
Greeley, CO 80632
Attorney General
State of Colorado
1525 Sherman St., 5th Floor
Denver, CO 80203
Re: Notice of Claim of Tammarra and Forist Holmes
against Weld County and State of Colorado
pursuant to §24-10-109
Dear Sirs:
Claimants Tammarra and Forist Holmes hereby give the following notice of claim against
Weld County and the State of Colorado pursuant to §24-10-109 of the Colorado Revised Statutes:
1. The claimants are Tammarra and Forist Holmes, 682 S. 3rd, Brighton, Colorado
80601. The claimants' attorneys are Mark Sisun & Associates, P.C., 90 Madison Plaza, Suite
302, Denver, Colorado 80206.
2. At approximately 11:40 p.m. on March 13, 1998 claimant Forist Holmes was
driving, and claimant Tammarra Holmes was a passenger in, a motor vehicle travelling
westbound on Colorado highway 76 near Colorado highway 52 in Weld County. A horse that
had escaped from its pasture struck the claimants' vehicle. A fence along the frontage road of
Colorado highway 76 failed to restrain the horse from entering the highway.
r. Cc . ,0„.� 981651
City Attorney, Weld County
County Commissioners, Weld County
Attorney General, State of Colorado
August 27, 1998
Page 2
3. The claimants are not aware of any public employee involved in the incident.
4. Claimant Tammarra Holmes suffered physical injuries on account of the incident,
including, but not necessarily limited to, injuries to the neck, back, face, eye, head, and hand.
Claimant Forist Holmes suffered loss of consortium.
5. Claimant Tammarra Holmes requests monetary damages in the amount of
$150,000 from Weld County and the State of Colorado. Claimant Forist Holmes requests
monetary damages in the amount of $150,000 from Weld County and the State of Colorado.
Very truly yours,
MARK SISUN & ASSOCIATES, P.C.
By:
Mark A. Sisun
Steven P. Hemmerle
SPH/lkk
cc: Tammarra and Forist Holmes
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