Claim Woodman, Myra & StanleyBITTER LAW OFFICES
485 LOCUST STREET
DUBUQUE, IOWA 52001
Office: 563-588-4608
Fax: 563-5~8-0103
June 27, 2002
TO:
The Honorable Mayor and Members of the City Council
City of Dubuque
City Hall
50 17 St.
Dubuque, IA 52001
Residence
Joe: 563-582-1768
Tom: 563-582-7545
NOTICE OF CLAIM
This claim is being delivered to you on behalf of Myra K. Woodman and her husband, Stanley
Woodman.
On May 8, 2002, at approximately 1:30-2:30 p.m., Myra K. Woodman was attempting to enter
the Dubuque Law Enforcement Center through the Iowa Street entrance. She was there on
business and was a business invitee.
Right in front of the door, the sidewalk is uneven and raised, and poses an unreasonable risk to
customers and business invitees. Myra Woodman was entering the Law Enforcement Center for
the purpose of processing a license and obtaining the signature of the Dubuque Chief of Police.
Because of the uneven condition of the sidewalk, Myra Woodman tripped with her left foot on
the raised portion of the sidewalk and fei1. She was able to recover, but put a strain on her right
knee in the process. She felt that the strain would subside and did not see a doctor until May 20,
2002. During that period of time, the pain continued and actually increased. The pain consists
primarily of pain in the right knee, behind the right knee, and down the front of her leg into her
ankle and foot. Mrs. Woodman also has pain in the right ankle and foot.
Mrs. Woodman was initially treated by Dr. Samuel Sullivan of the Sullivan Chiropractic Clinic,
2699 Kennedy Road, Dubuque, Iowa, 52002 on May 20th and 22nd. Dr. Sullivan felt that he was
unable to alleviate the pain, so Mrs. Woodman made an appointment with Dr. Craig C. Schultz at
Medical Associates who prescribed pain medication for her, took X-rays of her knee and
indicated that he did not find any broken bones.
The pain continues and persists, and on May 24, 2002, she was seen again by Dr. Schultz who
has now referred her to Dr. Terence Alexander. Myra Woodman has an appointment to see Dr.
Charles Morrow. All of the treating physicians except the Sullivan Chiropractic Clinic are with
Medical Associates in Dubuque.
June 27, 2002
Page 2
Myra Woodman is the owner and operator of the Aragon Tap and the Central Tap in Dubuque,
Iowa and she has had replacement help for which she has incurred expenses.
The exact extent of injury is not yet known and may not be known for some time.
Because of the pain and impairment that she is now suffering, her husband, Stan Woodman,
makes a claim for the loss of consortium, as well as for the expense of her medical bills.
The amount of this claim is indeterminate at this time because of the uncertainty of the medical
future.
Mr. and Mrs. Woodman reside at 11625 Kennedy Rd., Dubuque, IA, 52001. A photocopy of the
sidewalk showing the defect is attached hereto. The sidewalk is located directly in front of the
Law Enforcement Center, is a public sidewalk and is under the control and jurisdiction of the
City of Dubuque.
Respectfully submitted,
Joso~ph J. Bitter
JJB/km(6)
Enc.
cc: Mr. and Mrs. Stanley Woodman