Claim Link, LoisIn the IOWA DISTRICT COURT for DUBUQUE COUNTY
LOIS M. LINK,
Plaintiff,
VS.
CITY OF DUBUQUE, IOWA,
Defendant.
No.LACV053117
ORIGINAL NOTICE
TO THE ABOVE-NAMED DEFENDANT(S):
CITY OF DUBUQUE, IOWA
City Hall, 50 West 13th Street
Dubuque, IA 52001
YOU ARE NOTIFIED that a Petition was filed on the 21 st day of August, 2002, in the office of the Clerk
of this Court naming you as the Defendant in this action. A copy of the Petition and Demand for Jury Trial are
attached to this Notice. The attorneys for the Plaintiff(s) are Michael J. Coyle and Danita L. Galdick, Fuerste,
Carew, Coyle, Juergens & Sudmeier, P.C., whose address is 200 Security Building, 151 West 8th Street, Dubuque,
Iowa 52001, and whose phone number is (563) 556-4011; facsimile number (563) 556-7134.
You must serve a Motion or Answer within twenty (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,
at the county courthouse in Dubuque, Iowa. If you do not, judgment by default may be rendered against you for
the relief demanded in the petition.
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 (563) 589-4448. (If you are hearing impaired, call Relay iowa
TrY at 1-800-735-2942).
Dubuque County Courthouse
Dubuque, Iowa
_________________
CLERK OF COURT
Dubuque, Iowa
IMPORTANT:
YOU ARE ADVISED TO SEEK LEGAL ADVICE AT ONCE TO PROTECT
YOUR INTERESTS.
IN THE IOWA DISTRICT COURT
DUBUQUE COUNTY
LOIS M. LINK,
Plaintiff,
VS.
CITY OF DUBUQUE, IOWA,
Defendant.
No. 01311LACV053117
PETITION AT LAW AND JURY DEMAND
COMES NOW Plaintiffand for her cause of action, states as follows:
1. Plaintiffis and at all material times hereto was a resident of Dubuque,
Dubuque County, Iowa.
2. Defendant City of Dubuque, Iowa is a municipal corporation located
within Dubuque County, Iowa.
3. On or about September 17, 2000, Plaintiff Lois M. Link was walking on
the public sidewalk in front of 997 Mt. Loretta, Dubuque, Iowa, when she tripped and fell
on the concrete which was broken and displaced.
4. Plaintiff Lois M. Link's fall was a direct and proximate result of the
negligence, constituting fault, of Defendant, City of Dubuque, Iowa, in the following
particulars:
a) Failing to care for, supervise, inspect and control the public
sidewalk, in violation of Section 364.12, Code of Iowa;
b) Failing to maintain the public sidewalk in a safe condition, in
violation of Section 364.12, Code of Iowa; and
c)Failing to repair the defective sidewalk at the place where Plaintiff
tripped and fell, in violation of Section 364.12, Code of Iowa.
5. As a direct and proximate result of the fault of Defendant, City of
Dubuque, Iowa, the PlaintiffLois M. Link sustained damage and loss, including severe
personal injury, pain and suffering - both past and future, past and future disability, loss
of the enjoyment of life both past and future, and past and future health care expenses.
6. Plaintiff Lois M. Link's damage and loss far exceed the jurisdictional
limits of the Associate District Court.
WHEREFORE, PlaintiffLois M. Link prays for judgment against the Defendant
City of Dubuque, Iowa, in an amount that will fully, fairly, and adequately compensate
her for the damages she has sustained, for interest as provided by law, and court costs.
JURY DEMAND
COMES NOW Plantiff, Lois M. Link, and demands trial by jury upon all issues
herein properly so triable.
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FUERSTE, CAREW, COYLE,
JUERGENS & SUDMEIER, P.C.
By____________________
Michael J. Coyle 000001036
By______________________
Danita L. Galdick, 000016848
200 Security Building
151 West 8th Street
Dubuque, Iowa 52001-6832
Phone: (563) 556-4011
Fax: (563) 556-7134
Attorneys for PLAINTIFF.
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