Claim by Antonio MouzonTHE CITY OF
DUB11UE MEMORANDUM
Masterpiece on the Mississippi
TRACEY STECKLEIN
PARALEGAL
_—)ob
To: Mayor Roy D. Buol and
Members of the City Council
DATE: May 7, 2010
RE: Claim Against the City of Dubuque by Antonio Mouzon
Claimant Date of Claim Date of Loss Nature of Claim
Antonio Mouzon 04/30/10 04/29/10 Vehicle Damage
This is a claim in which claimant alleges that a City of Dubuque refuse truck struck
claimant's vehicle as the refuse truck was attempting to turn left onto Bennett Street
from McCormick Street.
This claim has been referred to Public Entity Risk Services of Iowa, the agent for the Iowa
Communities Assurance Pool.
cc: Michael C. Van Milligen, City Manager
Paul Schultz, Resource Management Coordinator
Antonio Mouzon
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 *ire /e,e14
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 13 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: P{ Y 1-ty 4l i 0 -3 0, \ -i_: bl
2. Address: 2 000 LAn, ■ti .S\ F. - � A v �
3. Telephone Number 2 -S 1 - t -i I Li
4. Date of Incident: LI 2 ` i - 7MA
5. Time of Incident: L. e r`n
6. Location of Incident (Be specific): y ? }�
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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.)
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10. Did police investigate? (If so, give names of officers.)
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8. What were weather conditions like?
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9. Give name and address of any witnesses:
11. Was anyone injured? (If so, give names, addresses, and extent of injuries).
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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.)
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13. What other damages do you claim, if any?
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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. yVhat amount do you claim from the City of Dubuque? \
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16. Why do you claim the City of Dubuque is responsible?
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17. Have you made any claim against anyone else for damages as a result of
this incident? (If yes, give name and address.)
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18. If the answer to Question 17 is yes, have you received any payment from that
source, and if so, in what amount?
Dated this
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04/29/2010 at 04:27 PM Job Number:
24443
Insured: ANTONIO MOUZON
Owner: ANTONIO MOUZON
Address: 2000 UNIVERSITY
DUBUQUE, IA 52001
Cellular: (254)285 -9614
Inspect
Location:
ABRA - DUBUQUE
Federal ID #:420782245
DBA: ANDERSON -WEBER INC
3400 CENTER GROVE DR
DUBUQUE, IA 52003
(563)556 -0696 Fax: (563)556 -1899
PRELIMINARY ESTIMATE
Written By: RICK KELLY
Adjuster:
Claim #
Policy #
Deductible:
Date of Loss:
Type of Loss:
Point of Impact:
Insurance CUSTOMER PAY
Company: Days to Repair
1997 NISS MAXIMA SE 6- 3.0L -FI 4D SED GREEN Int:TAN
VIN: JN1CA21D7VT201166 Lic: IA Prod Date: 07/1996 Odometer: 142340
Air Conditioning Rear Defogger Tilt Wheel
Cruise Control Intermittent Wipers Body Side Moldings
Dual Mirrors Console /Storage Fog Lamps
Rear Spoiler Clear Coat Paint Power Steering
Power Brakes Power Windows Power Locks
Power Antenna Power Mirrors AM Radio
FM Radio Stereo Cassette
Search /Seek Driver Air Bag Passenger Air Bag
4 Wheel Disc Brakes Cloth Seats Recline /Lounge Seats
5 Speed Transmission Aluminum /Alloy Wheels
NO. OP. DESCRIPTION QTY EXT. PRICE LABOR PAINT
1 FRONT BUMPER
2 O/H front bumper 0 0.00 1.8 0.0
3 ** Repl Qual Repl Parts CAPA Bumper 1 186.00 Incl. 2.5
cover all
4 Add for Clear Coat 0 0.00 0.0 1.0
5 GRILLE
6 Repl Grille assy w/o chrome 1 101.00 Incl. 0.5
7 Overlap Minor Panel 0 0.00 0.0 -0.2
8 Add for Clear Coat 0 0.00 0.0 0.1
9 FRONT LAMPS
10 ** Repl Qual Repl Parts LT Headlamp 1 189.00 Incl. 0.0
assy
11 Aim headlamps 0 0.00 0.5 0.0
1
04/29/2010 at 04:27 PM
24443
PRELIMINARY ESTIMATE
1997 NISS MAXIMA SE 6- 3.0L -FI 4D SED GREEN Int:TAN
NO. OP. DESCRIPTION
12 ** Repl Qual Repl Parts LT Signal
lamp assy from 1/95
13 ** Repl Qual Repl Parts LT Side
marker lamp from 1/95
14 ** Repl Qual Repl Parts LT Park /turn
lamp
15 HOOD
16 ** Repl Qual Repl Parts CAPA Hood
17 Overlap Major Non -Adj. Panel
18 Add for Clear Coat
19 Add for Underside(Complete)
20 FENDER
21 ** Repl Qual Repl Parts CAPA LT Fender
22 Overlap Major Adj. Panel
23 Add for Clear Coat
24 Add for Edging
25 Deduct for Overlap
26 Repl LT Fender liner
27 Repl Mud guard
28 Repl LT Front panel
29 Repl LT Sidemember assy
30 Deduct for Overlap
31 Blnd RT Fender
32 RADIATOR SUPPORT
33 Repl Radiator support
34 Overlap Minor Panel
35 Evacuate & recharge
36 Refrigerant recovery
37 Deduct for Overlap
38 ELECTRICAL
39 Repl Relay box front of battery
40 FRONT DOOR
41 Blnd LT Door shell
42# ** *ESTIMATE IS NOT COMPLETE.
MAY BE A TOTAL LOSS * * * **
Subtotals = =>
Parts
Body Labor
Paint Labor
Mechanical Labor
Paint Supplies
SUBTOTAL
Sales Tax
2
QTY EXT. PRICE LABOR PAINT
1 15.00
1 25.00
1 57.00
1 321.00
0 0.00
0 0.00
0 0.00
1 213.00
0 0.00
0 0.00
0 0.00
0 0.00
1 57.82
1 70.00
1 143.80 s
1 550.59 s
0 0.00
0 0.00
1 383.75 s
0 0.00
0 0.00 m
0 0.00 m
0 0.00
2338.43
Job Number:
1.2
0.0
0.0
0.0
2.0
0.0
0.0
0.0
- 0.4
Incl.
0.2
4.0
8.0
- 2.0
0.0
1 25.47 0.0
0 0.00 0.0
1 0.00 0.0
0.0
0.0
0.0
2.8
-0.2
0.5
1.4
2.0
-0.4
0.3
0.5
0.0
0.0
0.0
0.5
0.0
0.0
1.0
7.6 1.5
0.0 -0.2
1.4 M 0.0
0.4 M 0.0
- 1.0 0.0
0.0
1.2
0.0
23.7 14.8
2338.43
21.9 hrs @ $ 57.00 /hr 1248.30
14.8 hrs @ $ 57.00 /hr 843.60
1.8 hrs @ $ 67.00 /hr 120.60
14.8 hrs @ $ 35.00 /hr 518.00
$ 5068.93
$ 4550.93 @ 7.0000% 318.57
04/29/2010 at 04:27 PM Job Number:
24443
PRELIMINARY ESTIMATE
1997 NISS MAXIMA SE 6- 3.0L -FI 4D SED GREEN Int:TAN
GRAND TOTAL $ 5387.50
ADJUSTMENTS:
Deductible
CCC Pathways - A product of CCC Information Services Inc.
3
0.00
CUSTOMER PAY $ 0.00
INSURANCE PAY $ 5387.50
WARRANTY VALID ONLY WITH ORIGIONAL COPY OF YOUR RECEIPT PARTS SUBJECT TO
INVOICE NO GUARANTEE ON RUST ALL PARTS NEW, UNLESS OTHERWISE NOTED
THIS ESTIMATE HAS BEEN PREPARED BASED ON THE USE OF AFTERMARKET CRASH PARTS
SUPPLIED BY A SOURCE OTHER THAN THE MANUFACTURER OF YOUR MOTOR VEHICLE. ANY
WARRANTIES APPLICABLE TO THESE REPLACEMENT PARTS ARE PROVIDED BY THE
MANUFACTURER OR DISTRIBUTOR OF THESE PARTS RATHER THAN THE MANUFACTURER OF YOUR
VEHICLE.
WARRANTY VALID ONLY WITH ORIGIONAL COPY OF RECEIPT. PARTS SUBJECT TO INVOICE.
NO GUARANTEES ON RUST. ALL PARTS NEW, UNLESS OTHERWISE SPECIFIED.
Estimate based on MOTOR CRASH ESTIMATING GUIDE. Unless otherwise noted all items are derived
from the Guide AEF3798, CCC Data Date 04/05/2010, 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 2010 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.