Claim by David LinkTHE CTTY OF _~
DUB E MEMORANDUM
Masterpiece on the Mississippi
BARRY LINDAHL 1
CITY ATTORNEY
To: Mayor Roy D. Buol and
Members of the City Council
DATE:
RE:
Claimant
David J. Link
March 10, 2008
Claim Against the City of Dubuque by David J. Link.
Date of Claim
Date of Loss
Nature of Claim
02/29/08
02/04/08
Personal Injury/
Vehicle Damage
This is a claim in which the claimant alleges that as he was northbound on Jackson
Street near 17th Street, a City of Dubuque snow plow truck ran the stop sign while
eastbound on 17th Street and struck claimant's vehicle.
This claim has been referred to Public Entity Risk Services of Iowa, the agent for the Iowa
Communities Assurance Pool.
BAL:tIs
cc: Michael C. Van Milligen, City Manager
Jeanne Schneider, City Clerk
John Klostermann, Street & Sewer Maintenance Supervisor
David J. Link
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 balesq@cityofdubuque.org
.~ .,
CE.°
~~~~ ,:
CLAIM AGAINST THE CITY OF DUBUQUE, IOWA~~M ~
JJCC
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:
2. Address:
3. Telephon
4. Date of Lncident: ~ - ~ aD0
5. Time of Incident: ~ ,~~~(~ Q' • /y}?
6. Location of Incident (Be~specific):
8. What were weather conditions like?
~~o~~
9. Give name and address of anv witnesses:
~aOO3
~~
10. Did police investigate? (If so, give names of officers.)
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
11. Was anyone injured? (If so, give names, addresses, and extent of injuries).
., ~, n n ., _ e s
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.) A „ .
13. What other damages do you claim, if a
14. Have you been compensated for any partyor~al~of your claim by any
insurance company? (If so, give name and address of insurance company and
amount paid.)
15. What amount do you claim from the City of Dubuque?
16. Why do you claim the City of Dubuque is responsible?
17. Have you made any claim against anyone else for damages as a result of
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?
Dated this .~~ day of ~~-' . ~ 20- o~ -
`~1 ~ ~, ,~
(Sin r
6Z :8 4id 62 833 80
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(Print Name) ~~~~~~ J ~~
IA Driver Information Exchange Report
Dubuque Police Department
563.583-4410
u
N
I
T
001
Driver's Name - Last
LUDOWITZ
First
RANDALL
Middle
PAUL
Suffix.
MI
Address
193 STATE ST
City
DUBUQUE
State
IA
Z p Phone
52003-0000 (563) 557-2175 x
Gender
Male
Driver's License Number
Class
B
State
IA
Endorsements
N
Restrictions
NONE
Insurance Co.
IA COMMUNITY
Name
ASSURANCE
Insurance C. Phone k
Owner Company Name
CITY OF DUBUQUE
Insurance Policy
*
-
Owners Name - Last
First
Middle
Suffix
Address
50 W 13TH STREET
City
DUBUQUE
State
IA
Zip
62001-
VIN No,
1FVAC2DC95HV41871
Year
2005
Make
FRHT
Model
999
Style
TRK
Vehicie Confiyurs:kkr•
' 88 .
License Plate 0
OFFICIAL
State
IA
Year
2099
Most Damaged
02 - Right Front
Area
Approximate Cost to Repair or Repl t
$0.00
Y
u
N
T
202
Drivers Name - Last
LINK
First
DAVID
Middle
JOSEPH
Suffix
Date of Birth
Address
10282 MORNING DOVE LANE
City '
DUBUQUE
State
IA
Z p
52003.0000
Phone
(563) 557-1879 x
Gender Driver's License Numbs'
Male '
Class
C
State
IA
Endorsements
L
Restrictions
NONE
Insurance Co. Name Insurance C•• =l-„r . =
DEPOSITORS (800) 282.1446 x
Owner Company Name
-- -.
Insurance Policy #
PPX0009742107-4
Owner's Name - Last
LINK
First
DAVID
Middle
JOSEPH
Suffix
-
Address
10282 MORNING DOVE LANE
f City
` DUBUQUE
'State
IA
Zip
52003-0000
VIN No, 1 +'oar rMake
1D7HL12X135350195 12003 1 DODG
Model
DAK
Style
_ PK
Vehicle Configuration
_ 02
License Plate 0
974PNO
Stale
IA
Year
2008
Most Damaged Area
01 - Front
Approximate Cost to Repair or Repi... •
51,000.00
County f Accident occurred with n corporate limits of (city)
Dubuque-31 1Dubuque-2100
Literal Description
E 17TH ST and JACKSON ST
X-Coordinate Y-Coordinate
00691660 04708973
If accident occurred outside of city
limits show general vacinity: "NIA"
Direction Nearest City
"NIA" of 1 "NIA"
Route (Cardinal) ,
Travel Direction "N/A"
On Road, Street, or Highway:
JACKSON STREET
At Intersection with:
E 17TH STREET
Distance
"NIA"
Direction
"NIA" and
Distance
"NIA"
Direction
"NIA" of
Milepost Number
I "NIA" Or
Definable intersection, bridge, or railroad crossing
"NIA"
Officer
BELLIS, JEFFREY
Sedge No.
14
Law Enforcemenl Case Number
01-06.5049
Dale of Accident
02/04/2008
Time of Acc ideni
06:30 Hr;
02/09/2008 at 09:28 AM
94524
TURPIN DODGE OF DUBUQUE, LLC
90 KENNEDY RD
DUBUQUE, IA 52001
(563)583-5781 Fax: (563)556-6928
PRELIMINARY ESTIMATE
Written By: TERRY FORTMANN
Adjuster:
Insured: DAVID LINK Claim #
Owner: DAVID LINK Policy #
Address: 10282 MORNING DOVE LN Deductible:
DTJBUQUE, IA 52003 Date of Loss:
Other: (563)557-1879 Type of Loss:
Point of Impact:
Inspect
Location:
Job Number:
Insurance
Company: Days to Repair
2003 DODG DAKOTA 4X2 CLUB CAB SXT 6-3.9L-FI 2D P/U Int:
VIN: 1D7HL12X13S350195 Lic: Prod Date: Odometer:
Air Conditioning Intermittent Wipers Dual Mirr ors
Privacy Glass Clear Coat Paint Power Ste ering
Power Brakes AM Radio FM Radio
Stereo Search/Seek CD Player
Anti-Lock Brakes (2) Driver Air Bag Passenger Air Bag
4 Wheel Disc Brakes Cloth Seats Bucket Se ats
5 Speed
------- Transmission Overdrive
------------------------------------ Styled St eel Wheel s
NO.
-------
OP.
---------- -----
DESCRIPTION
------------------------- ----
QTY -----------
EXT. PRICE ---------
LABOR P -------
AINT
1 ------
FRONT BUMPER ---- ----------- --------- -------
2 O/H front bumper 1.4
3 Repl Bumper cover upper 1 364.00 Incl. 2.4
black/painted w/o fog lamps
4 Add for Clear Coat 1.0
5 Repl License mount 1 30.25 0.2
6 Repl Impact bar 1 126.00 Incl.
7 HOOD & GRILLE
8 Repl Hood 1 292.00 1.4 2.8
9 Add for Clear Coat 1.1
10 Add for Underside(Complete) 1.2
11 Repl Striker & catch 1 45.95 Incl.
12 Repl Lock 1 39.60 0.3
13 Repl Grille paint to match 1 235.00 Incl. 1.5
14 Overlap Major Adj. Panel -0.4
15 Add for Clear Coat 0.2
16 Repl Grille bracket 1 62.95 Incl.
17 FRONT LAMPS
1
02/09/2008 at 09:28 AM
94524
Job Number:
PRELIMINARY ESTIMATE
2003 DODG DAKOTA 4X2 CLUB CAB SXT 6-3.9L-FI 2D P/U Int:
---------
N0. -------
OP. -------------------------------
DESCRIPTION ---------------
QTY EXT. PRICE ---------
LABOR --------
PAINT
---------
18 -------
Repl -------------------------------
LT Headlamp assy ------
1 -------
219.00 -- ---------
0.5 --------
19 Aim headlamps 0.5
20 AIR CONDITIONER & HEATER
21 Repl Condenser 1 327.00 m 1.6
22 Evacuate & recharge m 1.4
23 FENDER
24* Rpr LT Fender assy 3.5 2.0
25 Overlap Major Adj. Panel -0.4
26 Add for Clear Coat 0.3
27 FRAME
28* Rpr Frame assy 112" wheelbase 4.0
29# BUG SHEILD 1 95.00 0.5
30# FRONT END ALIGNMENT 1 1.5 M
31# CAR COVER 1 5.00 T
32# BLEND BOTH DOORS 1 0.5 2.2
33#
---------
------- HAZARDOUS WASTE
---------------------- 1 5.00 T
---------
Subtotals =_> ------
1 -------
846.75 -- ---------
17.3 --------
13.9
Parts 1836.75
Body Labor 15.8 hrs @ $ 52.00/hr 821.60
Paint Labor 13.9 hrs @ $ 52.00/hr 722.80
Mechanical Labor 1.5 hrs @ $ 52.00/hr 78.00
Paint Supplies 13.9 hrs @ $ 32.00/hr 444.80
Sublet/Misc.
--------------------
- 10.00
SUBTOTAL ----- ------- -- ---------
$ --------
3913.95
Sales Tax $ 3913.95 @ 7.0000 273.98
GRAND TOTAL $ 4187.93
ADJUSTMENTS:
Deductible 0.00
CUSTOMER PAY $ 0.00
INSURANCE PAY $ 4187.93
2
02/09/2008 at 09:28 AM Job Number:
94524
PRELIMINARY ESTIMATE
2003 DODG DAKOTA 4X2 CLUB CAB SXT 6-3.9L-FI 2D P/U Int:
Estimate based on MOTOR CRASH ESTIMATING GUIDE. Unless otherwise noted all items are derived from
the Guide DR3TF97, CCC Data Date 01/01/2008, and the parts selected are OEM-parts manufactured by
the vehicles Original Equipment Manufacturer. OEM parts are available at OE/Vehicle dealerships.
OPT OEM (Optional OEM) or ALT OEM (Alternative OEM) parts are OEM parts that may be provided by or
through alternate sources other than the OEM vehicle dealerships. OPT OEM or ALT OEM parts may
reflect some specific, special, or unique pricing or discount. OPT OEM or ALT OEM parts may
include "Blemished" parts provided by OEM's through OEM vehicle dealerships. Asterisk (*) or
Double Asterisk (**) indicates that the parts and/or labor information provided by MOTOR may have
been modified or may have come from an alternate data source. Tilde sign (-) items indicate MOTOR
Not-Included Labor operations. Non-Original Equipment Manufacturer aftermarket parts are described
as AM, Qual Repl Parts or Comp Repl Parts which stands for Competitive Replacement Parts. Used
parts are described as LKQ, Qual Recy Parts, RCY, or USED. Reconditioned parts are described as
Recond. Recored parts are described as Recore. NAGS Part Numbers and Benchmark Prices are
provided by National Auto Glass Specifications. Labor operation times listed on the line with the
NAGS information are MOTOR suggested labor operation times. NAGS labor operation times are not
included. Pound sign (#) items indicate manual entries. Some 2006 vehicles contain minor changes
from the previous year. For those vehicles, prior to receiving updated data from the vehicle
manufacturer, labor and parts data from the previous year may be used. The Pathways estimator has
a complete list of applicable vehicles. Parts numbers and prices should be confirmed with the
local dealership.
CCC Pathways - A product of CCC Information Services Inc.
3