Claim Roth, B & Daniel, James Tl:m LAW OFFICES OF
ROTH & HENKELS
~4n ~sociation of Sole Praxtitioners
1400 UNY, mRSrn' AVENU~ SUr~;~ D
DUBUQUE, IA .52001-5931
James J. Roth*
Francis Wm. Henkels
Benjamin J. Roth
City of Dubuque
ATTN: Jeanne F. Schneider, City Clerk
50 West 13th Street
Dubuque, IA 52001
RE: Our Client: James A. Daniel
Date of lnjury: 3/09/02
Telephone: (563) 557-1611
Facsimile: (568) 557-9775
E-mail: BRoth@RothAndHenkels.com
June 20, 2002
Dear Ms. Schneider:
Please be advised that our office has been retained to represem James Daniel regarding
personal injuries he sustained on or about March 9, 2002 at near the front entrance to the Diamond
Jo Casino.
On said date, Mr. Daniel was leaving the casino and walking toward his car which was
parked in the parking lot when he tripped on a fence and fell to the ground. The fence was laying
flat on the ground near the front entrance of the casino and was apparently supposed to be a
barricade surrounding construction work in the area. Following the incident, Mr. Daniel was taken
to Mercy Health Center by ambulance for medical treatment.
Legal counsel for the Diamond Jo Casino, Attorney Brian Kane, has i~ffonned me that the
incident in which Mr. Daniel was injured took place on City of Dubuque property.
Please consider this letter as a notice of claim. This notice should be provided to your
liability insurance carder as soon as possible.
We would ask that your insurance representative and/or attorney contact our office within
fifteen (15) days from the date of this letter. If we do not hear from you or your representative
within said time, we will assume that you have no interest in discussing this matter and will proceed
accordingly. Thank you for your time.
Sincerely,
Benjamin J. Roth
B JR