Claim by Justine PeskoTHE CITY OF
DUBJJE MEMORANDUM
Masterpiece on the Mississippi
TRACEY STECKLEIN
PARALEGAL
To: Mayor Roy D. Buol and
Members of the City Council
DATE: December 8, 2010
RE: Claim Against the City of Dubuque by Justine Pesko
Claimant Date of Claim Date of Loss Nature of Claim
Justine Pesko 12/06/10 12/03/10 Vehicle Damage
This is a claim in which claimant alleges that as she was waiting for police to arrive after
being involved in a one -car accident, her vehicle was rear -ended by the police squad
car.
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
Mark Dalsing, Chief of Police
Justine Pesko
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
Dec. 6. 2010 8:30AM 9134025404
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 13 St., Dubuque, IA 52001. It will then be referred to
the appropriate department for investigation and to the City Attorneys 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 o asto whether your claim will or will not be paid.
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1. Name of Claimant: _L aline,
i fP_t3 kU
2. Address: G lam (� tC� 1PS��ir Ke Zi„tx t h Le trLDzi ni
3. Telephone Number: 5 - q -'Z21 (y
4. Date of incident: I Z- 3- i O
5. Time of Incident: La a0 Pr(\
6. Location of Incident (Be specific): km'rrt
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.)
Was I\Avo }ved l ainJ \-e. vQhick CJ, ccideyrk, G
— the_ - pn L 1ocE ,r 1 m 1t ckyri ve-
8. What were weather conditions like? f CAI � , V�h bt/ 30,21 Cass
9. Give name and address of any witnesses: O
cv he \ (° .i. c hded
10. Did police investigate? (If so, give names of officers -)
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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 er describe basis for ascertaining extent of damage.)
• • E'r .Y dali1G. cy — 1-c C Q_I'I l L.L.L.
- to _ t. g • ad _ 1 I I PC i 67
No. 2294 P. 2 �
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Dec. 6. 2010 8:30AM 9134025404 No. 2294 P. 3
13. What other damages do you claim. If any? e
14. Have you been compensated for any part or ell of your claim by any insurance company? (If so, give name and
address of insurance company and amount paid.)
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15. What amount do you claim from the City of Dubuque? J
16. Why do you claim the City of Dubuque Is responsible? Ai et
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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
(Signature)
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Dec. 6. 2010 8:30AM 9134025404
TRAVELERS)
Travelers Insurance Company
7465 W. 132 St.
Overland Park, KS 66213
1 (800) 348 -6944
www.travelers. corn
To: C 1 C \-e-Y K
Fax number: '1i)3 C,1 c)c
From:
Fax number: 1 (888) 840 -811.
Date: ` 2 w
Regarding:
Phone number for follow -up:
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No. 2294 P. 1
Comments:
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FAX
To: City of Dubuque
Company:
Fax: 5635890890
Phone:
From: HMKING @travelers.com
Fax:
Phone:
E -mail:
NOTES:
File Cabinet Document Attach - Claim Number U8C2397
This communication, including attachments, is confidential, may be subject to legal privileges, and is
intended for the sole use of the addressee. Any use, duplication, disclosure or dissemination of this
communication, other than by the addressee, is prohibited. If you have received this communication in
error, please notify the sender immediately and delete or destroy this communication and all copies
Date and time of transmission: Tuesday, December 07, 2010 1:34:22 PM
Number of pages including this cover sheet: 06
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Here is the estimate for Justine Pesko. Thank you.
Title: Estimate Print Image -E01 Attach: 5736110E- 2483- 46BB- A726- 17D72BB83C32.PDF
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12/07/2010 AT 11:15 AM
101048
WRITTEN BY: SARAH SCHEEL 1- 913 - 402 -3818 12/07/2010 11:14 AM
ADJUSTER: HEATHER KING (913)402 -5354
INSURED: BRIAN PESKO
OWNER: BRIAN PESKO
ADDRESS: 960 MANCHESTER CT
LAKE ZURICH, IL 60047 -1298
EVENING: (847)540 -0933
BUSINESS: (847)283 -2563
INSPECT JUSTINE RESIDENCE
LOCATION: 529 FENELON PLACE APT 4
DUBUQUE, IA 52001 -0000
REPAIR
FACILITY:
1999 HOND ACCORD LX 4 -2
VIN: 1HGCG5647XAl21923
AIR CONDITIONING
CRUISE CONTROL
CONSOLE /STORAGE
POWER BRAKES
POWER MIRRORS
FM RADIO
SEARCH /SEEK
CLOTH SEATS
OVERDRIVE
NO. OP.
12/7/2010 1:38:01 PM PAGE 3/006 Fax Server
RECEIVED
10 DEC -7 Phi 2: 27
City Ceri :'s Office
Dubuque, IA
TRAVELERS
OVERLAND PARK CLAIM OFFICE
FOR SUPPLEMENTS CALL 888 - 299 -7456, PROMPT 2
PO BOX 2930
OVERLAND PARK, KS 66201
(800)348 -6944
ESTIMATE OF RECORD
.3L -FI 4D SED TAN INT:TAN
LIC: 6904722 IL PROD DATE
REAR DEFOGGER
INTERMITTENT WIPERS
CLEAR COAT PAINT
POWER WINDOWS
POWER TRUNK /GATE RELEASE
STEREO
DRIVER AIR BAG
BUCKET SEATS
FULL WHEEL COVERS
1 QUARTER PANEL
N 2* RPR LT INNER PANEL ASSY US BUILT
3 ADD FOR CLEAR COAT
4 R &I MUD GUARD SET, REAR
5 REAR BODY & FLOOR
6* RPR REAR BODY PANEL
7 ADD FOR CLEAR COAT
8 R &I REAR PANEL TRIM
9 R &I LT TRUNK SIDE TRIM
10* R &I SPARE COVER
11 REAR BUMPER
N 12* REPL LKQ BUMPER COVER +25%
13 ADD FOR CLEAR COAT
U8C2397001
25YW03YQ
CLAIM #U8C2397001
POLICY #PT5010A9871528221011
DATE OF LOSS: 12/03/2010 AT 06:31 PM
TYPE OF LOSS: COLLISION
POINT OF IMPACT: 7. LEFT REAR
1
DAY: (847)409 -2216
OTHER
6 DAYS TO REPAIR
LICENSE #
ODOMETER: UNK
TILT WHEEL
DUAL MIRRORS
POWER STEERING
POWER LOCKS
AM RADIO
CASSETTE
PASSENGER AIR BAG
AUTOMATIC TRANSMISSION
DESCRIPTION QTY EXT. PRICE LABOR
1 312.50*
4.0*
0.3
6.0*
0.4
0.5
0.2*
PAINT
2.0*
0.4
1.2
0.5
1.2* 3.2*
1.3
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12/07/2010 AT 11:15 AM U8C2397001
101048 25YW03YQ
ESTIMATE OF RECORD
1999 HOND ACCORD LX 4- 2.3L -FI 4D SED TAN INT:TAN
NO. OP. DESCRIPTION QTY EXT. PRICE LABOR PAINT
14# SHIPPING PER JIM @ SWIFTS 1 25.00
15# RPR SET UP & MEASURE
16# RPR UNIBODY FRAME REPAIR
17# REPL SEAM SEALER /CAULKING 1 20.00
LINE 2 : REPAIR INNER QUARTER PANEL
REFINISH LOWER INNER QUARTER ONLY
LINE 12 : SWIFTS AUTO SALVAGE - JIM
800 - 627 -8788
QT# 125793
ESTIMATE NOTES:
VEHICLE IS DRIVABLE- IMPORTANT- PLEASE PROVIDE THE SHOP OF YOUR CHOICE WITH A
COPY OF THIS (TRAVELERS) APPRAISAL SO THAT PARTS CAN BE ORDERED AND RECEIVED
BY THE SHOP PRIOR TO LEAVING YOUR VEHICLE FOR REPAIRS.
THIS ESTIMATE IS FOR REAR DAMAGE ONLY FRONT DAMAGE IS PART OF ANOTHER CLAIM
PRIOR DAMAGE NOTES:
RRD DING
LRD DING
DING IN FUEL DOOR
SUBTOTALS ==> 357.50
PARTS
BODY LABOR
PAINT LABOR
FRAME LABOR
PAINT SUPPLIES
SUBTOTAL
SALES TAX
TOTAL COST OF REPAIRS $ 2152.42
ADJUSTMENTS:
DEDUCTIBLE 500.00
TOTAL ADJUSTMENTS
NET COST OF REPAIRS
2
2.0
2.0 F
16.6 8.6
357.50
14.6 HRS @$ 54.00 /HR 788.40
8.6 HRS @$ 54.00 /HR 464.40
2.0 HRS @$ 60.00 /HR 120.00
8.6 HRS @$ 35.00 /HR 301.00
$ 2031.30
$ 1730.30 @ 7.0000% 121.12
$ 500.00
$ 1652.42
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101048 25YW03YQ
ESTIMATE OF RECORD
1999 HOND ACCORD LX 4- 2.3L -FI 4D SED TAN INT:TAN
ALL SUPPLEMENTS MUST BE PRE - APPROVED BY TRAVELERS. PLEASE CALL 888 - 299 -7456
(PROMPT 2)
SUPPLEMENT REPAIR CHARGES MAY BE SUBJECT TO REJECTION UNLESS APPROVED BY
TRAVELERS PRIOR TO REPAIRS.
THIS INSTRUMENT IS NOT AN AUTHORIZATION TO REPAIR. REPAIR MUST BE
PRE - AUTHORIZED BY THE VEHICLE OWNER.
VEHICLE OWNER MAINTAINS THE RIGHT TO REPAIR VEHICLE AT A REPAIR FACILITY OF
THEIR CHOICE.
PLEASE PRESENT THIS ESTIMATE TO THE REPAIR FACILITY PRIOR TO REPAIRS.
ILLINOIS LAW REQUIRES THAT VEHICLE REPAIRERS MUST BE LICENSED IN ACCORDANCE
WITH SECTION 5 -301 OF THE ILLINOIS VEHICLE CODE.
ESTIMATE BASED ON MOTOR CRASH ESTIMATING GUIDE. UNLESS OTHERWISE NOTED ALL
ITEMS ARE DERIVED FROM THE GUIDE AEG4422, CCC DATA DATE 10/15/2010, 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.
CCC PATHWAYS - A PRODUCT OF CCC INFORMATION SERVICES INC.
3
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101048 25YWO3YQ
ESTIMATE OF RECORD
1999 HOND ACCORD LX 4- 2.3L - FI 4D SED TAN INT:TAN
ALTERNATE PARTS USAGE
AFTERMARKET PARTS
AFTERMARKET SELECTION METHOD: MANUALLY LIST
NO. OF TIMES USER WAS NOTIFIED THAT AN AFTERMARKET PART WAS AVAILABLE: 1
NO. OF AFTERMARKET PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0
OPTIONAL OEM PARTS
OPTIONAL OEM SELECTION METHOD: MANUALLY LIST
NO. OF TIMES USER WAS NOTIFIED THAT AN OPTIONAL OEM PART WAS AVAILABLE: O
NO. OF OPTIONAL OEM PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0
RECONDITIONED PARTS
RECONDITIONED SELECTION METHOD: MANUALLY LIST
NO. OF TIMES USER WAS NOTIFIED THAT A RECONDITIONED PART WAS AVAILABLE: 1
NO. OF RECONDITIONED PARTS THAT APPEAR IN THE FINAL ESTIMATE: 0
RECYCLED PARTS
NO. OF TIMES USER WAS NOTIFIED THAT A RECYCLED PART WAS AVAILABLE:
NO. OF RECYCLED PARTS THAT APPEAR IN THE FINAL ESTIMATE:
4