Claim by Betty Tigges Confidential
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This communication and any attachments may contain information which is confidential
and privileged by law and is for the use of the designated recipient. If you are not the j
intended recipient, you are hereby notified that you have received this communication in
error, and that any review, disclosure, dissemination, distribution or copying of its contents
is prohibited. Please notify City of Dubuque immediately by telephone at (563)-589-4120 of
your receipt of these items and destroy the communication and any attachments
immediately. Further disclosure of this information may violate state and federal
restrictions.
Confidential information may include the following:
1) Social Security Number(s)
2) Medical/Health Information
3) Personnel/Disciplinary Information
4) Bank Account Information
5) Financial Information
6) Credit Card Numbers
If any documentation you desire to submit to the City of Dubuque contains any of the items above
this cover sheet must be attached directly to the confidential information and indicate the type of
information that is included.
I, hereby certify that the attached documents
include the following protected information:
Social Security Number(s) Bank Account Information
Medical/Health Information Financial Information
Personnel/Disciplinary Information Credit Card Number(s)
I understand that this information may be distributed within the City organization or to agents of the
City for processing and I hereby authorize the City to act accordingly taking all precautions to
protect my information from unnecessary distribution.
Signature Date
I have read the information above and do not have any confidential documentation to submit to the
City of Dubuque as part of this Claim Against the City j
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Signature u Date
CLAIM AGAINST THE CITY OF DUBUQUE, IOWA .
This written report constitutes your claim against the City of Dubuque, Iowa. You
should complete this form in full and attach any additional information that
supports your claim.
The claim must be filed with the City Clerk at City Hall, 50 West 13th St.,
Dubuque, IA 52001. It will then be referred to the appropriate department for
investigation and to the City Attorney's Office. Once that investigation is
completed, a report and recommendation will be submitted to the City Council.
You will be provided with a copy of that report and recommendation.
The final decision on all claims is made by the City Council. No employee of the
City of Dubuque has the authority to make any representation to you as to
whether your claim will or will not be paid.
1. Name of Claimant: c. Tti
2. Address: o° w �-�`, ,' ;, r T 7
3. Telephone Number 6- 3
4. Date of Incident:
5. Time of Incident: `
6. Location of Incident Be specific):
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7. Describe the accident or occurrence that caused injury or damage. (Give full
details upon which you base your claim. If a City employee was involved, give
the employee's name.) ;a
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8. What were weather conditions like?
9. Give name and address of any witnesses:
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10. Did police investigate? (If so, give names of officers.)
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11. Was anyone injured? (If so, give names, addresses, and extent of injuries).
12. Was any damage done to property? (If so, describe property and the extent
of damages. Attach estimates of damages or describe basis for ascertaining
extent of damage.)
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13. What other damages do you claim, if any?
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14. Have you been compensated for any part or all of your claim by any
insurance company? (If so, give name and address of insurance company and
amount paid.),,
15. What amount dc� you claim from the Ci of Dubuque?
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16. Why do you claim the C) of Dubuque is responsible?
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17. Have you made any claim against anyon a®Ise"i�or'damage as a re fIIt�o
this incident? (If yes, give name and address.)
18. If the answer to Question 17 is yes, have you received any payment from that
source, and if so, in what amount?
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Dated this 3 day of6 0 t »? i� 20 /t) cit
(Signature), << _ I"
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CO
ICY 1` C �o
(Print Na e) U (7
G®UNTO
Courthouse' " p (563)589-4436
720 Central ►� 'R Fax:(563)589-7819
Dubuque, IA 52001 E-mail:treasurer@dbgoo.org
Bu Jac.
Eric Stierman
Dubuque County Treasurer
October 26, 2015
Betty Tigges
2082 Admiral St
Dubuque, iowa 52001
Dear Betty,
Enclosed are copies of all your tax bills.Three of them have been adjusted per orders from the
County Assessor.They have adjusted bill marked on them. If you were to compare them to your current
bills, they will be $70.00 lower than what you paid in September, 2015.We lowered the bills for March,
2016. Any questions, call me at 589-7820.Thanks Betty, it was a pleasure talking to you.
Sincerely,
4E��:
ric Stierman
Dubuque County Treasurer
,RECEIVED
IN THE IOWA DISTRICT COURT FOR DUBUQUE COUNTY
15 NOV -6 P : 2$
THOMAS J. MILLER, )
} City C'ieCk`S Office
Plaintiff, ) f�ltl q e [
}
vs. ) Case No. Lk .
CITY OF DUBUQUE, )
Defendant. )
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ORIGINAL NOTICE
TO THE ABOVE-NAMED DEFENDANT(S):
You are notified that a Petition is on file in the Office of the Clerk of the above Court. A
copy of the Petition is attached. The Attorney for the Petitioner is Natalia H. Blaskovich,
Reynolds & Kenline, L.L.P., whose address is 110 East 9h Street, P.O. Box 239, Dubuque, Iowa
52004-0239. That attorney's phone number is (563) 556-8000; facsimile number (563) 556-
8009; email: blaskovich@rkenline.com.
You must serve a Motion or Answer within 20 days after service of this Original Notice
upon you, and, within a reasonable time thereafter,file your Motion or Answer,with the Clerk of
Court for Dubuque County by utilizing electronic filing at
https://www.iowacotirts.state.ia.us/Efi I e. If you do not, judgment by default may be rendered
against you for the relief demanded in the Petition. You must e-file pursuant to Iowa Court
Rules Chapter 16 for general rules and information on electronic filing. Chapter 16,division VI
relates to protection of personal information in court filings.
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If you need the assistance of auxiliary aids or services to participate in court because of a
disability, immediately call your District ADA coordinator at (319) 833-3332. Persons who are
hearing impaired may call Relay Iowa TTY (1-800-735-2942).
YOU ARE ADVISED TO SEEK LEGAL ADVICE AT ONCE TO PROTECT YOUR
INTERESTS.
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STATE OF IOWA JUDICIARY Case No. LACV103732
County DublugUe
Case Title MILLER V CITY OF DUBUQUE
THIS CASE HAS BEEN FILED IN A COUNTY THAT USES ELECTRONIC FILING.
Therefore,unless the attached Petition and Original Notice contains a hearing date for your appearance,or unless you obtain an
exemption from the court,you must file your Appearance and Answer electronically.
You must register through the Iowa Judicial Branch website at httr)://www.iowacourts.state.ia.us/Efile and obtain a log in and
password for the purposes of filing and viewing documents on your case and of receiving service and notices from the court.
FOR GENERAL RULES AND INFORMATION ON ELECTRONIC FILING,REFER TO THE IOWA COURT RULES CHAPTER
16 PERTAINING TO THE USE OF THE ELECTRONIC DOCUMENT MANAGEMENT SYSTEM:
http://www:iowacourts.state.ia.us/Efile
FOR COURT RULES ON PROTECTION OF PERSONAL PRIVACY IMCOURT FILINGS,REFER TO DIVISION VI OF IOWA
COURT RULES CHAPTER 16:http://www.iowacourts.state.ia.us/Efile
Scheduled Hearing.-
If
earing:If you require the assistance of auxiliary aids or services to participate in court because of a disability,immediately call your district
ADA coordinator at(319)833-3332 . (If you are hearing impaired,call Relay Iowa TTY at 1-800-735-2942.)
Date Issued 11104/2015 03:33:20 PM
District Clerk of Dubuque County
/s/ Ana Unger
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E-FILED 2015 NOV 04 9:32 AM DUBUQUE-CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT FOR DUBUQUE COUNTY
THOMAS J. MILLER, }
Plaintiff, ) ��
vs. )
Case No. LRCV
CITY OF DUBUQUE, )
Defendant. )
PETITION AT LAW
MES NOW the Plaintiff Thomas J. Miller, b
CO Y and through his attorney, Natalia H.
Blaskovich, and in support of his cause of action, states the following:
I. Plaintiff, Thomas J. Miller, was a resident of Dubuque County, Iowa, at the time
of his injury. Plaintiff now resides in Round Lake Beach, Illinois.
2. The Defendant, the City of Dubuque, was at all times material hereto, a
municipality duly incorporated under the law of the State of Iowa, located at 50
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West 13`h Street, Dubuque, Iowa 52001.
3. The incident which is the basis of this cause of action occurred on or about
January 10, 2014, when Plaintiff exited a city bus at a bus stop near the parking
ramp adjacent to the Diamond Jo Casino in Dubuque, Iowa, which is owned and
maintained by Defendant, City of Dubuque.
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4. The weather conditions on January 10, 2014 were cold, icy, and snowy.
5. On the same date and place described above, Plaintiff, Thomas J. Miller, exited a R
city bus and, as he did, his foot slid on the snow that had a layer of ice underneath
it and slid under the bus.
6. On that date and at that location, Defendant, City of Dubuque, was the owner of
the property where Mr. Miller fell.
7. At that same date and location described above, Defendant, City of Dubuque,
failed to de-ice a common area where pedestrians were expected to walk.
8. The bus operator, a City of Dubuque employee, stopped the bus in a snow and ice
covered area.
9. Mr. Miller slipped and fell as a result of the condition described above.
E-FILED 2015 NOV 04 9:32 AM DUBUQUE-CLERK OF DISTRICT COURT
10. Mr. Miller was injured as a result of falling while exiting the bus.
11. On that date and at that location, the Defendant, City of Dubuque, knew or should
have known that the dangerous conditions on its property involved an
unreasonable risk of harm to the Plaintiff and other persons on the premises.
12. On that date and at that location the Defendant, City of Dubuque, should have
anticipated that persons like the Plaintiff on the premises would not discover or
realize the danger.
13. The City of Dubuque failed to properly, train, supervise and/or monitor its
employee which was a proximate cause of the plaintiff s injuries in this case.
14. The City of Dubuque is a common carrier of passengers who failed to exercise the
appropriate care to protect Plaintiff from danger.
15. Defendant, City of Dubuque, further had adequate time prior to the injury to have
taken measures to remedy or protect against the dangerous conditions.
16. On that date and at the location, the Defendant, City of Dubuque, acted or failed
to act in one or more ways and in so acting was negligent. The Defendant, City of
Dubuque,was negligent including,but not limited to, in the following particulars: I
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a) failing to maintain a safe condition of its premises;
b) failing to take corrective measure to eliminate the dangerous conditions;
C) failing to warn others of the dangerous conditions;
d) failing to properly inspect its premises;
e) failing to properly maintain the premises;
f) failing to identify dangerous conditions;
g) failing to instruct and supervise employees operating its buses on how to
park buses in an area safe for passengers to exit;
h) failing to properly ensure that its bus passenger was not injured;
i) failing to operate its business in a non-negligent manner as expected under
Iowa law.
17. As a result of the negligent acts including but not limited to those listed above,
Defendant City of Dubuque's negligence proximately caused Plaintiff, Thomas
Miller, damages including, but not limited to:
a) medical expenses,both past and future;
b) pain and suffering, both past and future;
C) past and future emotional distress and mental anguish;
d) loss of enjoyment of life;
e) past and future loss of function of body;
f) past and future lost wages; and,
g) any other damage(s)recognized under Iowa law.
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E-FILED 2015 NOV 04 9:32 AM DUBUQUE-CLERK OF DISTRICT COURT
WHEREFORE, Plaintiff, Thomas J. Miller, herein prays that judgment be entered against
the Defendant City of Dubuque, for damages listed above including, but not limited to:
medical expenses, both past and future;
pain and suffering; both past and future;
past and future emotional distress and mental anguish;
past and future lost wages;
permanent disability;
loss of enjoyment of life;
past and fixture loss of function of body;
any other damage(s) recognized under Iowa law;and,
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court costs and interest. f
Which said amount meets jurisdictional requirements and all other relief the Court deems just in
the premises.
JURY DEMAND u
The Plaintiff hereby demands this case be tried to a jury. Ij
THO SAS J. MI , BIZ., Plaintiff;
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By:
Na alfa H. Blaslkoviclh -AT0000901 - _...
of
REYNOLDS &KENLINE, L.L.P.
110 East 91h Street
P.O. Box 239
Dubuque, IA 52004-0239
Tel: (563) 556-8000
Fax: (563) 556-8009
Email: blaskovich(a2,rkenline.com
ATTORNEYS FOR PLAINTIFF
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E-FILED 2015 NOV 04 9:32 AM DUBUQUE-CLERK OF DISTRICT COURT
Rule 1.1901—Form 16: Expedited Civil Action Certification
' In the Iowa District Court forDUBUQUE _ County
THOMAS J. MILLER Civil case no. L.kCV I b3 T
Plaintiff
Full name of PlainfiY;first,middle, last
Expedited Civil Action Certification
vs.
CITY OF DUBUQUE
Defendant
Full name of'Defendant:,first,middle,last
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PlaintiffThomas J. Miller _.�_-_—�—_: together with Plaintiffs attorney
Name of Plaintiff
Natalia H. Blaskoyicl _ _,elect to bring this lawsuit as an Expedited
� Name of attorney
Civil Action under Iowa Rule of Civil Procedure 1.281.
Plaintiff certifies that the sole relief sought is a money judgment and that all claims(other than
compulsory counterclaims) for all damages by or against any one party total$75,000 or less,
including damages of any kind, penalties, prefiling interest, and attorneys'fees, but excluding
prejudgment interest accrued after the filing date, post judgment interest, and costs.
Plaintiff certifies the following:
1. I am a plaintiff in this action. j
2. If I am represented by ari attorney, I'have conferred with my attorney about using the J
Expedited Civil Action procedures.available to parties in the State of Iowa.
1 1 understand that by electing to proceed under Expedited Civil Action procedures, the
total amount of my recovery will not exceed $75,000, excluding prejudgment interest
accrued after the filing, post judgment interest, and court costs. Additionally, no single
defendant can be liable for more than $75,000 to all plaintiffs combined, excluding
prejudgment interest accrued after the filing, post judgment interest, and court costs.
4. 1 understand that if a jury were to award more than $75,000 as damages to me, or if a
Jory were tc award more than $75,000 in total against a single defendant,the trial
judge would reduce the amount of the judgment to $75,000, plus any applicable
_ interest and court costs to which I may be entitled.
With this knowledge, I agree to proceed under the Expedited Civil Action procedures.
Dated this ynday of N()V t Yob e.r' 2015 .
Plaintiff
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August 2014 Rule 1.1901—Form 16 Page 1 of 2
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E-FILED 2015 NOV 04 9:32 AM DUBUQUE-CLERK OF DISTRICT COURT
Rule 1,1901—Form 16:Expedited Civil Action Certification,continued
Oath and Signatures
I, Thomas J. Miller certify under penalty of perjury and pursuant to the
Print Plaintiff's name
laws of the State of Iowa that the preceding is true and correct.
NbV,M6tr q 2015
Month _ Day - Year
- r' Thomas J. Miller
Clrandw—utertsi�nc tq iffPlaint ff Full name ofPlaint ff first, middle, last
Nat is . Blas vich
in ' "s a rney Is n rme, if applicable N
ig>yalurerJatloi,ney, if applicable
V
Reynolds & nline. L.L.P.
Law firm, if applicable r
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1.10 East 9th Street Dubuque, IA 52001
Mailing addr. of attorney(or Plaintiff if unrepresented) 1
563-556-8000 !i
Telephone no. of attorney(or Plaintiff if unrepresented) i
blaskovich@rkenline.com
Email address of attorney(or Plaintiff if unrepresented)
Additional email address, if available
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August 2014 Rule 1.1901—Form 16 Page 2 of 2
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