Claim Worden RaymondCLAIM 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 W. 13th St., Dubuque, IA 52001. 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 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: Raymond Worden Jr. by guardians Raymond Sr & Bambi Worden
2.Address: 1503 Washington St., Dubuque, Iowa 520001
3. Telephone Number: 563 556 4301
4. Date of Incident: 10-14-01
5. Time of Incident:
6. Location of Incident (Be specific): Comiskey Park, Dubuque, Iowa
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 employee's name.)
See letter dated November 30, 2002
8. What were weather conditions like?
9. Give name and address of any witnesses:
Dakota Losh, minor, address unknown
10. Did police investigate? (If so, give names of officers.)
Dubuque Police Officer Fairchild CR #01-43407
11. Was anyone injured? (If so, give names, addresses, and extent of injuries).
Yes, Raymond Worden, Jr. 1503 Washington St. Dubuque Iowa, 52001, injuries, head, back, face, jaw, and lip.
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.)
Unknown at this time. Claimants' bicycle may have been damaged. Will advise on property damage.
13. What other damages do you claim, if any?
Bodily injury and possible property damage bicycle.
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.)
Heritage 1806073G
15. What amount do you claim from the City of Dubuque?
Unknown at this time.
16. Why do you claim the City of Dubuque is responsible?
The Comiskey Park is run by the City of Dubuque Park Division.
17. Have you made any claim against anyone else for damages as a result of this incident?
(If yes, give name and address.)
No
18. If the answer to Question 17 is yes, have you received any payment from that source, and if so, in what amount?
Dated at Dubuque, Iowa this 12th day of February, 2003
/s/ Ray Worden 2 12 03
(Signature)
(Print Name)
(Rev. 1/00 & 7/01)
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 W. 13th St., Dubuque, IA 52001.
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 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: ~ {~ ~ ~ 0Y~_~ ~--~, ['~ ~ (.J~J~%0- ~(L~,~
3. Telephone Number: ~(~5- ~ - )~0'[
4. Date of Incident:
5. Time of Incident:
6. Location of Incident (Be specific):
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
8. What were wea. ther conditions like?
9. Give name and address of any witnesses:
10. Did police i~vestigate? ,(Jf~so, give_names of office, rs.) ~ .~ _ .
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.)
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.)
15. What amount do you claim from the City of Dubuque.~'[_~..~, ~Pb ~L
17. Have you made any claim against anyone else for damages as a result of this incident?
(If y~s, 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?
Dated at Dubuque, Iowa this /C'~
· /" -(Signa{ure)
/ (Print Name)
, 20 ~_~-~
2
(Rev. 1/00 & 7/01)
BLAIR & FITZSIMMONS,
ATTORNEYS AT LAW
LES ~¥[. BLAtR JIJ ~
~ALSO LICENSED IN ILL~OIS
P.e.
850 ¥~rHITE STREET
DUBUQUe., IOWA 5200
TELEPHONE: (563) 588-1970
FACSnmLE: (563) 556-4033
Ei, m4i L: DubuqueLaw(~aol. com
Attorney William Blmn
300 Main Street
Suite 330
Dubuque, Iowa 52001
November 30, 2002
Re: Raymond Worden
Dear Mr. Blum:
I have been retained by Raymond and Bambi Worden to proceed with a personal injury
claim on behalf of their ten (10) year old son, Raymond Worden, Jr. for injuries he sustained
retative to unmarked cables in Comiskey Park, Dubuque, Iowa.
On October 14, 2001, Raymond Warden Jr. was riding his bicycle in Comiskey Park and
accidentally ran into some type of cable, unmarked, strildng his right mandible area Mr. Worden
fell offhis bicycle striking his head on the pavement, which caused him to lose consciousness.
He fell on his back and hurt his arm as well. He has right facial edema and right facial abrasion
and laceration on his lip.
After the initial fall, Mr. Worden's mother was contacted and he was taken to the hospital
for his injuries. A police report was filed with the Dubuque Police Department. Officer
Fairchild responded. The report number is CR #: 01-43407. Photographs were taken
immediately after the accident. The photo~aphs taken depict the area in which the cables exist
and are marked by Mr. Worden's hand to demonstrate the inability to see these cables. There are
also photographs of Mr. Worden's facial lacerations the day of the accident and currently.
Once all the medical docttmenmtion is received Jn our office, we will submit a demand to
you for purposes of an amicable settlement and resolution of this claim. Please contact our office
Nove~ber 30, 2002J
Page 2
and provide us with your reference nmnber, contact information and the necessary information to
expeditiously process this claim.
As you can see from the photographs, Mr. Worden has suffered both physical injury as
well as mental injury due to the notice ability of this injury. Kindly, provide the policy limits that
would apply to this injury on the above referenced date of those at Comiskey Park, Dubuque,
Iowa.
In the meantime, if you have any questions or concerns regarding this matter, please
contact me to discuss. I look forward to receiving the above requested information from you
soon. Thank you for your anticipated cooperation to resolve this claim.
~m~rt G. Hoover
Blair & Fitzsimmons, P.C.
850 White Street
Dubuque, Iowa 5200 t -7035
Cc: Raymond and Bambi Worden