Suit by Dorothy L. Lester vs. City of DubuqueDOROTHY L. LESTER,
(SEAL)
vs.
IN THE IOWA DISTRICT COURT IN AND FOR DUBUQUE COUNTY
Plaintiff,
CITY OF DUBUQUE, AN IOWA
MUNICIPAL CORPORATION,
Defendant.
ORIGINAL NOTICE
TO THE ABOVE -NAMED DEFENDANT(S): City of Dubuque
Case No. d 13 /l CA - a ki.5 4 70
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You are notified that a "Petition" has been filed in the office of the clerk of this
court naming you as the defendant in this action. A copy of the "Petition" (and any documents
filed with it) is attached to this notice. The name and address of the attorney for the plaintiff(s) is
James A. Trannel. The attorney's phone number is (563) 557 -7360; facsimile number: (563)
557 -1018.
You must serve a motion or answer within 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 disability, immediately call your district ADA coordinator at (563) 589 -4448. (If you
are hearing impaired, call Relay Iowa TTY at 1- 800 - 735- 2942.)
CLERK OF COURT
Dubuque County Courthouse
Dubuque , Iowa 52001
IMPORTANT: YOU ARE ADVISED TO SEEK LEGAL ADVICE AT ONCE TO PROTECT
YOUR INTERESTS
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IN THE IOWA DISTRICT COURT IN AND FOR DUBUQUE COUNTY
DOROTHY L. LESTER,
vs.
Plaintiff,
CITY OF DUBUQUE, AN IOWA
MUNICIPAL CORPORATION,
Defendant.
PETITION
Case No.
Comes now Plaintiff, Dorothy L. Lester, and for cause of action states:
1. Dorothy L. Lester is now, and at all times relevant hereto, was a resident of the
City of Dubuque, Dubuque County, Iowa.
2. Defendant, City of Dubuque, is an Iowa Municipal Corporation. One of the
services the City of Dubuque provides is transit service, through a
division/department known as "Keyline Transit Services ".
3. On or about July 30, 2009, Plaintiff, Dorothy L. Lester, was a fare- paying rider on
a Keyline Transit Service bus in the City of Dubuque, Iowa. As Dorothy L. Lester
existed said bus at the termination point of her trip, she fell from the said bus to
the street.
4. As a result of said fall Dorothy L. Lester sustained injuries and damages.
5. A proximate cause of Plaintiff's injuries and damages was the negligence of the
Defendant, City of Dubuque and Keyline Transit Services, in the following
particulars:
a.) In failing to maintain the bus on which Plaintiff rode in a safe
condition;
b.) In failing to warn Plaintiff that the bus concerned was having problems
which could impact her exiting therefrom;
c.) Although having the opportunity to do so, in failing to assist the
Plaintiff in existing the bus;
d.) In failing to safeguard Plaintiff from injury.
6. The amount of damages claimed by Plaintiff exceeds the jurisdictional limit for
small claims court.
Wherefore Plaintiff, Dorothy L. Lester, prays that the Court enter judgment
against the Defendant in a reasonable amount adequate to compensate the Plaintiff for her
injuries, together with interest as provided by law, and the costs of this action.
DOROTHY L. LESTER, Plaintiff
By:
Hughes & Tramiel, P.C.
1154 Iowa Street
Dubuque, Iowa 52001
Phone: (563) 557 -7360
Fax: (563) 557 -1018
Attorney for Plaintiff