Claim by Austin EpplerTHE CTfY OF
DUB E MEMORANDUM
Masterpiece on the Mississippi
TRACEY STECKLEIN /,
PARALEGAL
To: Mayor Roy D. Buol and
Members of the City Council
DATE:
RE:
Claimant
January 28, 2009
Claim Against the City of Dubuque by the Austin Eppler
Date of Claim
Austin Eppler
01 /23/09
Date of Loss
12/27/08
Nature of Claim
Vehicle Damage
This is a claim in which claimant alleges that a City of Dubuque snowplow truck lost
control and slid into the back of claimant's truck near the corner of Steller Eagle Drive
and Bald Eagle Drive.
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
John Klostermann, Street & Sewer Maintenance Supervisor
Austin Eppler
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 / EnnAIL tsteckle@cityofdubuque.org
--, ,~
~1~1'~, ~~~~Lli /f~~--j
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:
2. Address:
~yT
~~%~c rl
~~1~ ~'
'~ ;
3. Telephone Number
~~~
4. Date of Incident: rr ~ - ~~ ~ ~ ~
5. Time of Incident: G1 " .~ y ~'~1
6. Location of Incident (Be specific): /
~'?-~ u ~~n~ 0~1 ~'~.t- r" ry~yltr~ cyT ~~/~C~ ~e/~ d<, ,~-- ~~j~;~b ~iHL`- `~',
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.) I !
1 .~/al'/z~ ~~,K.r ~5' fr~~K ~v i~r~ S~~W ~~ %cc.y ,~ci Gnd N-t aJ' ~-
9. Give name and address of any witnesses:
10. Did police investigate? (If so, give names of officers.)
~5~3~ ~ ~o-/yoFs
8. What were weather conditions like? J
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.) 1
~ 1~~ S •~ St-~h14~ 5 C~3~- G ~~"~C~-C°- ~t~1~
13. What other damages do you claim, if any?
U Vvz-~-
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 do you claim from the City of Dubuque?
Ohl , :,.~~~- ,,~ ~ ~-'In ~;:-~ i ~- ~ ~~s`t-~
16. Why7do, you claim the City of DubJ1uqu_e is res/ponsible?
;~/~
hr i a ,~ ~ ; ,1 S r?G~ ~J /o:,/ rt f ~~ ~'!~f" T~°c' i ~ ~ Y ~ .~ vn ~ u r
nf' inr?{Yo~ C~nd hIt ~~/ t~~=~'~,
17. Have you made any claim against anyone else for damages as a result of
this incident? (If yes, give name and address.)
f
,'
18. If the answer to Question 17 is yes, have you received any payment from that
source, and if so, in what amount? ~,
[~ ~'
c"7`~ ~
-_ ~ r- N
Dated this-'day of ~ ~Z ~, ~ , 20 ~ ~• ~=; =- `~'
-t- _
ro
%L ~ ~~ _- ~-.. N
(Signature) - y~ ~o ~
(Print Name)
~G
,-~
~_
1`
.__
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.)
,~ n`J'E`EY~1MLi1h l~S'~r~l~-~~~-t-4.'G1f" M~lr~~-CY1Ght:¢.. JL~{°~rJ~so~^
~~
+ ~ G ~ ~ 9 c.-. izl ~. S
13. What other damages do you claim, if any?
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.)
l~~C~
15. What amount do you claim from the City,of Dubuque?
16. Why do, you claim the City of Dubuque is responsible?
hr i ~ ~~ c .~ ,~ S' f ~~ ~ o ~,/ f ~ '~`~(' % _r T 1/ S~d tJdl G~ rJ ~`
17. Have you made any claim against anyone else for damages as a result of
this incident? (!f yes, give name and ad dress.)
., .;
i 1/ ~
18. If the answer to Question 17 is yes, have you received any payment from that
source, and if so, in what amount? o
~
~ ~ ~G
Dated thisday of ~ ~Z.
a,~ - ,.20 ~~ ~ `'`~- N
`'' '_ J
~~
~ ~° ~ 3 ~
(Signature)
~ p
~ ;-~~
~; ~~ ~~~~' ~~ T
(Print Name)
01/23/2009 at 02:33 PM
30799
BRIMEYSR ADTO BODY
License #:30799 Federal ID #:421436480
10709 COLLISION DR.
DUBUQUE, IA 52001
(563)583-4456 Fax: (563)583-1838
PRELIMINARY ESTIMATE
Written By: BOB COOK
Adjuster:
Insured: AUSTIN EPPLER Claim #
Owner: AUSTIN EPPLER Policy #
Address: 2144 GOLDEN EAGLE DR Deductible:
DUBUQUE, IA 52001 Date of Losa:
Cellular: (563)580-1408 Type of Losa:
Point of Impact:
Inspect
Location:
Job Number:
Insurance
Company: Days to Repair
2001 CHEV K1500 4X4 SILVERADO EXT 8-5.3L-FI 4D SHORT GRAY Int:
VIN: 2GCEK19T2112 89598 Lic: Prod Date: Odometer:
Tilt Wheel Intermittent Wipers Dual M irrors
Clear Coat Paint Power Steering Power Brakes
AM Radio FM Radio Stereo
Search/Seek Anti-Lock Brakes (4) Driver Air Bag
Passenger Air Bag 4 Wheel Disc Brakes Rear S tep Bumper
Automatic Transmission 4 Wheel Drive Overdr ive
Styled Steel Wheels
N0. OP. DESCRIPTION
-
-- QTY EXT. PRICE LABOR P
------------------------ AINT
-------
------------
1 ---- ---------------------------
--
PICK UP BOX
2 Repl LT Side panel 1 948.56 10.0 3.1
3 Add for Clear Coat 1.2
4 Add for Inside 1.5
5 R&I R&I box assy 2.5
6* Rpr Tail gate 2.5 2.1
7 Overlap Major Adj. Panel -0.4
8 Add for Clear Coat 0.3
9 Repl LT Decal "Z71" 1 25.70 0.3
10* R&I LT Body side mldg Chevrolet 0.3
black/chrome
11# RETAPE MLDG 1 0.3
12 Repl Nameplate "SILVERADO" 1 53.06 0.2
13 Repl Nameplate "CHEVROLET" 1 43.25 0.2
14 R&I Spoiler 0.3
15 R&I Handle bezel painted green 0.2
16 REAR LAMPS
17 Repl LT Combo lamp assy 1/2 & 3/4 1 146.73 Incl.
ton
18# R&I BED LINER 0.5
19# MASKING COVER 1 5.00
20# UNDER COAT & SEAM SEALER 1 15.00 0.3
21 OTHER CHARGES
22# E.P.C. 1 5.00
------------ ---- --------------------------------
Subtotals =_> -----
1 -------
242.30 ------------
17.6 -------
7.8
Parts 1237.30
Body Labor 17.6 hrs ~ $ 53.00/hr 932.80
Paint Labor 7.8 hrs ~ $ 53.00/hr 413.40
Paint Supplies 7.8 hrs ~ $ 32.00/hr 249.60
Other Charges 5.00
---------------------
SUBTOTAL ----- ------- -----------
$ -------
2838.10
Sales Tax $ 2588.50 Q 7.0000 ~ 181.20
GRAND TOTAL $ 3019.30
ADJUSTMENTS:
Deductible o.oo
1
01/23/2009 at 02:33 PM Job Number:
30799
PRELIMINARY ESTIMATE
2001 CHEV K1500 4X4 SILVERADO EXT 8-5.3L-FI 4D SHORT GRAY Znt:
CUSTOMER PAY $ 0.00
INSURANCE PAY $ 3019.30
Estimate based on MOTOR CRASH ESTIMATING GUIDE. Unless otherwise noted all items are derived from
the Guide DR1GH99, CCC Data Date 01/02/2009, 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 2009 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.
YAGER AUTO BODY INC
4488 DODGE ST
DUBUQUE, IA 52003-2600
PHN: 563 557 7376 FAX: 563 557 1709
**" PRELIMINARY ESTIMATE "*'
12/31/2008 09:57 AM
Owner
Owner: AUSTIN EPPLER
Address: 2144 GOLDEN EAGLE DR. Cell: (563)580-1408
City State Zip: Dubuque, IA 52001 FAX:
Ins action ~ '
~_........_,,...,,,,.._.. ._... .........,.._...,__.,.__._._.....,._,..,.._,,,,...~. ._~_...__ ...................__,.,.~.a
Inspection Date: 12/30/2008 04:00 PM
Driveable: Yes Rental Assisted:
Appraiser Name: CJ YAGER
_.e~_u-, _. _ _..__.M.~~w~..,,.w.-.,~._..._
Re airer ..._.~..~..._-__ .w_,.~......~..~.-.._ .~.._.-._.._,M_.
~~._._ _
_~..w._.
~..-~..._......_.__.(
Repairer YAGER AUTO BODY Contact:
Address: 4488 DODGE ST Work/Day: (563)557-7376
City State Zip: Dubuque, IA 52003 Work/Day:
Vehicle
2001 Chevrolet Silverado K1500 LS 4 DR Ext Cab Short Bed
8cyl Gasoline 5.3
4 Speed Automatic
Lic.Plate: VIN: 2GCEK19T211289598
Mileage: 85,000 Mileage Type: Actual
Ext. Color: GRAY Int. Color:
Ext. Refinish: Two-Stage Int. Refinish: Two-Stage
Dama es
~___.... S_.__...~___ _. _ _ _ ~___._,_.
___._____.__...._..._..._________.__.___..._.__
Line Op Description ADJ% B% Price Labor
1 Replace OEM Panel,Bedside Outer LT $678.62 $563.50
2 Refinish Panel,Bedside Outer LT $186.20
3 R & I Assembly MIdg,Bedside Pnl Lwr OF $14.70
4 Replace OEM Decal,Bedside Panel LT $25.70 $9.80
5 Repair PnI,T/Gate Outer Repr $98.00
6 Refinish PnI,T/Gate Outer Repr $176.40
7 R & I Assembly N/Plate,Tailgate $9.80
8 R & I Assembly N/Plate,Tailgate $9.80
9 R & I Assembly Handle,Tailgate Outer $9.80
10 R & I Assembly Bezel,Tailgate Handle INC
11 R & I Assembly Bed Liner R & I $24.50
12 Replace Economy Taillamp Assembly LT $94.00 INC
12 Items
..~.....~. _.~____ _
Totals _.w.~..__~-._
'
Parts $798.32
Paint Materials $222.00
Body Labor $739.90
Refinish labor $362.60
Tax $133.06
Estimate Total 52,255.88
Insurance Pay: 52,255.88
Customer Pay: 50.00
12!37/2008 02:23 PM Page 1 of 2