Claim by Michael Haun 5 6 09THE CITY 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
May 8, 2009
Claim Against the City of Dubuque by the Michael Haun
Date of Claim
Michael Haun
05/06/09
Date of Loss
Nature of Claim
05/01/09 Vehicle Damage
This is a claim in which claimant alleges that his vehicle which was parked in front of
1845 Greendale Street was struck by a City of Dubuque police squad car.
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
Kim Wadding, Chief of Police
Michael Haun
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 tsteckle@cityofdubuque.org
,~
CLAIM AGAINST THE CITY OF DUBUQUE, IOWA
"I"I~is written report constitutes your claim against the City of Dubuque, Iowa. You should
complete this form in full and attach any additional informatian that supports your cleir,°~.
7 he Claim must be filed with the City Clerk at City Hall, 5Q W. 13t" St., Dubuque, IA 520Q1. It
will then be referred by the City Council to the appropriate department for investigation.
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
TI"IF CITY OF DUBUQUE HAS THE AUTHORITY TO MAKE ANY REPRESENTATION TC7 Y~)U'
A~ TO WHETHER YOUR CLAIM WILL OR WILL NOT BE PAID.
1. Name of Claimant: ~ ~ L -~ ~- c i H~A ~ N
2. Address: Zt ~t-1 ILc`I 'VV~~~ l~~i~vcx~~c, ~A ~"Z~c.2
3. Telephone Number: 5 6 ~ -- ~9 ~ - 5 `i2 $ __._...~.
~. Date of Incident: 5 , I ' Z vt~~ .._._.
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5. Time of Incident: y ~ ---
6. Location of Incident (Be specific): V ~ ~ L.~~ k~5 s~a2iLE~ L~ F-,a~~~
t~N -t'~E S~-Q~~T ~c'2~crL~i iwl ~~~NT ~r I~y'S 6~cs.~p~1-tC fir.
7. DESCRIBE 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
c~n~ployee's name.)
IM,~ V ~ i~-~- t [ ~~ Lv~ S L ~ c~R-+..~~/ i ~1 QtL~ ~ ~t--r 10 ~-1 S ~ c.cN 1~ R L C e- T .
~~s S
r4 N t7 3,q- c_ ~Lc 7 ~ ~-- -t-o ,,M-`( ~ Q'-2 iL~~ V ~ r~ f ~ ~ e: ,
8. What were weather conditions like? L i x,42, _
~3. Give name and address of any witnesses: ~~cyL-E ~ ~k vt~l - 1 '1>~~ V L ~NOr~ i~ ~ t
Ti~~: ~ ~ a--..t ~ t-t-s~.~.~.ti - ~e ~ ~ ~3~ eH ~ oa. >M ~ C N~~~ ~ ~. k-E2 A t li~,.r.t _ Z l b`-1 1~~ './ i.~,a7
'1 a. Did police investigate? (If so, givennnames of officers.)
~i ~ ~ [- Q E T tr ~ 1~- t.r10aQT'C I O LT ~l L;~ ~' a
`3p~xT~2 • LT. 3f4x'TE~ ~- -/eJ 4~ ~~eNE ~4N~ TaaiL rti`S c~
11. Was anyone injured? (If so, give names, addresses, and extent of injuries). ~-,o~,A bL ~
Y'~y ~/Ei-}-L L~e
~~~~~
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~ 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.)
.¢~,An.,q. (~~ tel. ,q S ~ m ~ ~- ~-~ Y v l
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13. What other damages do you claim, if any? ~NL ~~_ ~~.t~A-b l~~__._..~___,
1~b. Have you been compensated far any part or all of your claim by any insurance
company? (If so, ive name and address of insurance company and amount paid.)
15. What amount do you claim from the City~oif- Dubuque?
I~..M n . , r.1 T__ a T"" ~ ~'~} I !25 ~~ ~~ ~ ~ T~ ~'A L ~ ~ ~ ~ ~ ~ - SEA
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? ~ ~ ,,
Gated at Dubuque, Iowa this ~ day of /~~~~ 207.
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(Rev. 1100 & 7/01)
(Signature)
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0/04/2009 at 10:21 AM Job Number:
18174
RILEY AUTO SALES C'~'"" ~~ ~ j~j~ sb
Federal ID #:420957277
4455 DODGE STREET ~`~) ~~vG~ i~~~~~SCy-~
DUBUQUE, IA 52003 •~•
(563) 588-2326 Fax: (563) 583-1327 L,,~. cJ(~ ?~~~CT~
PRELIMINARY ESTIMATE
Written By: DAVE DEMOSS
Adjuster:
Insured:
Owner:
Address:
Day:
Evening:
Inspect
Location:
Insurance
Company:
MICHAEL HAUN
MICHAEL HAUN
2184 KEYWAY
DUBUQUE, IA 52002
(563)590-5928
(563)590-5928
2007 MITS ENDEAVOR 4X4 SE 6-3.8L-FI 4D UTV Int:
Days to Repair
VIN: 4A4MN31S97E077699 Lic: Prod Date: Odometer:
Air Conditioning Rear Defogger Tilt Wheel
Cruise Control Keyless Entry Theft Deterrent/Alarm
Dual Air Condition Rear Window Wiper Steering Wheel Controls
Message Center Tinted Glass Dual Mirrors
Console/Storage Luggage/Roof Rack Clear Coat Paint
Power Steering Power Brakes Power Windows
Power Locks Power Driver Seat Power Mirrors
Heated Mirrors AM Radio FM Radio
Stereo Search/Seek CD Changer/Stacker
Anti-Lock Brakes (4) Driver Air Bag Passenger Air Bag
Head/Curtain Air Bags Front Side Impact Air Bag 4 Wheel Disc Brakes
Traction Control Stability Control Leather Seats
Bucket Seats Heated Seats Trailering Package
Automatic Transmission 4 Wheel Drive Overdrive
Aluminum/Alloy Wheels
-----
---
NO. OP.
-------- -------------------------------
DESCRIPTION
---------------------- -----
QTY E --------------------------
XT. PRICE LABOR PAINT
1 ---------
FRONT BUMPER ----- --------------------------
2 Repl Bumper cover 1 292.72 2.1 2.8
3 Add for Clear Coat 1.1
4 Repl LT Reinf bracket 1 16.75 0.2
5 Repl LT Bezel all 1 18.42 Incl.
6 COOLING
7 Repl Trans cooler w/o trailer pkg 1 311.87 m 1.2
8 Repl Trans cooler bracket center 1 5.52
9 Repl LT Trans cooler bracket outer 1 5.68
Claim #
Policy #
Deductible:
Date of Loss:
Type of Loss:
Point of Impact:
1
~~~~
,~ X5/04/2009 at 10:21 AM
18174
Job Number:
PRELIMINARY ESTIMATE
2007 MITS ENDEAVOR 4X4 SE 6-3.8L-FI 4D UTV Int:
-----------------------------------------------
NO. OP. DESCRIPTION
------------- ---------------
QTY EXT. PRICE
-- ---------
LABOR
- --------
PAINT
--------
----------------------------------
10 Repl RT Trans cooler bracket outer
------------- -------------
1 5.87
-- --------
--
--
-
----------------------------------
Subtotals =_> -------------
656.83 ---------
3.5 -
-
-
3.9
Parts ~ 656.83
Body Labor 3.5 hrs @ $ 54.00/hr 189.00
Paint Labor 3.9 hrs @ $ 54.00/hr 210.60
Paint Supplies
-------------
- 3.9 hrs @ $ 35.00/hr 136.50
-
-----
SUBTOTAL --------------- ---------
$ --------
1192.93
Sales Tax $ 1056.43 @ 7.OOOOo 73.95
GRAND TOTAL $ 1266.88
ADJUSTMENTS:
Deductible 0.00
----------------------------------------------------
CUSTOMER PAY $ 0.00
INSURANCE PAY $ 1266.88
THIS ESTIMATE IS BASED ON A VISUAL INSPECTION AND DOES NOT INCLUDE ADDITIONAL
PARTS OR LABOR THAT MAY BE REQUIRED TO COMPLETE REPAIRS. PART PRICES ARE
CURRENT AND SUBJECT TO INVOICE.
WE FEATURE A LIFETIME WORKMANSHIP LIMITED WARRANTY - SEE OUR WRITTEN WARRANTY
FOR COMPLETE DETAILS.
LIFETIME PAINT PERFORMANCE GUARANTEE USING APPROVED PPG PRODUCTS AND A LIFETIME
GUARANTEE ON OVERALL WORKMANSHIP IS VALID AS LONG AS YOU THE VEHICLE STATED
HEREIN.
2
G~
~,~'%04/2009 at 10:21 AM
x'18174
Job Number:
PRELIMINARY ESTIMATE
2007 MITS ENDEAVOR 4X4 SE 6-3.8L-FI 4D UTV Int:
Estimate based on MOTOR CRASH ESTIMATING GUIDE. Unless otherwise noted all items are derived from
the Guide ARP6260, CCC Data Date 03/02/2009, 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.
3