Claim by Thomas Miller THE CITY OF
LTBE MEMORANDUM
Masterpiece on the Mississippi
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TRACEY STECKLEIN
PARALEGAL I
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To: Mayor Roy D. Buol and
Members of the City Council
DATE: March 19, 2015
RE: Claim Against the City of Dubuque by Thomas Miller, filed by Attorney
Natalia Blaskovich
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Claimant Date of Claim Date of Loss Nature of Claim
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Thomas Miller 03/17/15 01/10/14 Personal Injury �!
This is a claim in which claimant alleges that as he exited a City bus near the bus stop
adjacent to the Port of Dubuque Parking Ramp, he slipped and fell on an icy sidewalk,
fracturing his left ankle.
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This claim has been referred to Public Entity Risk Services of Iowa, the agent for the Iowa
Communities Assurance Pool. N
cc: Michael C. Van Milligen, City Manager
Tim Horsfield, Parking Systems Supervisor
Jodi Johnson, Transit
Natalia Blaskovich, Esq.
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OFFICE OF THE CITY ATTORNEY DUBUQUE, IOWA
SUITE 330, HARBOR VIEW PLACE, 300 MAIN STREET DUBUQUE, IA 52001-6944
TELEPHONE (563)583-4113/FAx (563)583-1040/EMAIL tsteckle@cityofdubuque.org
EaREYNOLDS & IENLINE L.L.P.
LAW FIRM SINCE 1890
WILLIAM J. MATERS
CHADWYN D. COX
MARK J, SULLIVAN
JOHN T. NEi4IMERS
TODD N. KLAYATAUSKAS*+
KIM C. RODDICK*
NATAIJA H EI.ASKOVLCH+
GINA L. KRAMER+
ZEKE R. McCARTNEY+
MATTHEW W. BOLEYN
*ALSO LICENSED IN
ILLINOIS
+ALSO LICENSED IN
WISCONSIN
#LICENSED IN
WISCONSIN
March 6, 2015
City of Dubuque
City Attorney's Office
Harbor View Place, Ste, 330
300 Main Street
Dubuque, IA 52001
RE: Our Client:
Date of Incident:
To whom it may concern:
Thomas Miller
01/10/2014
This firm represents Thomas Miller with respect to injuries he sustained
after slipping and falling on ice on January 10, 2014 in the city of Dubuque,
Iowa.
THIS LETTER CONSTITUTES AN OFFER OF SETTLEMENT AND
ALL STATEMENTS, CONCLUSIONS AND REPRESENTATIONS
CONTAINED HEREIN ARE EXPRESSLY MADE TO YOU AS PART OF
THE OFFER OF SETTLEMENT.
The settlement and demand are based upon the facts and issues of law
enumerated below. Mr. Miller was taken by ambulance to Mercy Medical
Center Emergency Room for injuries he sustained as a result of the fall.
DOB: Height: - inches
Gender: Male Weight: pounds
Medical Specials: $5,374.44
Date of First "Treatment:
INJURIES:
January 10, 2014
Closed fracture of the ankle — left lateral malleolus fracture, abnormal gait,
ankle and/or foot joint stiffness, ankle joint pain, and muscle weakness.
110 East 9th Street, P.0, Box 239, Dubuque, Iowa 52004-0239
Phone: 56S-556-8000, Fax: 563-556-5009, E -Mail: office@rkenline.com, Web: rkenline.com