Suit by Christine PutnamIN THE IOWA DISTRICT COURT IN AND FOR DUBUQUE COUNTY
CHRISTINE PUTNAM,
Plaintiff,
vs.
CITY OF DUBUQUE,
Defendant.
)
Case No. 01311 LACV �Kli
ORIGINAL NOTICE
TO THE ABOVE -NAMED DEFENDANTS:
YOU ARE HEREBY NOTIFIED that a petition has been filed on the
day of July, 2012, 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 Petitioner's attorney is James
J. Roth, Roth Law Office, P.C., 1400 University Ave., Suite D, Dubuque,
Iowa 52001 (Phone: 563- 557 -1611; Fax: 563- 557 - 9775).
You must serve a Motion or Answer within twenty (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 720 Central Avenue in Dubuque, Iowa. If you do not, judgment
by default may be rendered against you for the relief demanded in the
Petition.
If you need assistance to participate in court due to a disability, call
the disability coordinator at 319 - 833 -3332. Persons who are hearing
impaired or speech impaired may call Relay Iowa TTY 1- 800 - 735 -2942.
Disability coordinators cannot provide legal advice.
(SEAL)
CLERK OF COURT
Dubuque County Courthouse
Dubuque, Iowa 52001
IMPORTANT: YOU ARE ADVISED TO SEEK LEGAL ADVICE AT ONCE TO
PROTECT YOUR INTERESTS.
IN THE IOWA DISTRICT COURT IN AND FOR DUBUQUE COUNTY
CHRISTINE PUTNAM,
Plaintiff,
vs.
CITY OF DUBUQUE,
Defendant.
)
Case No. 01311 LACV t:���
PETITION AT LAW
1. Plaintiff, Christine Putnam, was at all times material hereto
a resident of Dubuque, Dubuque County, Iowa.
2. Defendant, City of Dubuque, is a municipality located in
Dubuque County, Iowa.
3. On July 26, 2010, Plaintiff Christine Putnam was walking in
the street on property owned by the City of Dubuque at the intersection
of Thomas Place and Ascension Street in Dubuque, Dubuque County,
Iowa.
4. While Plaintiff was walking in the area of the intersection of
Thomas Place and Ascension Street, Dubuque, Dubuque County, Iowa,
she stepped onto an unmaintained and defective area of the street and
fell. As a proximate result of the fall, Plaintiff incurred severe and
permanent injuries.
5. The proximate cause of Plaintiff's fall and injuries was the
negligence of Defendant in the following particulars:
a. In failing to timely and adequately inspect the street;
b. In failing to timely and adequately repair the street;
c. In failing to exercise ordinary care in inspecting,
maintaining, and repairing the street;
d. In failing to warn of defects in the street.
6. As a proximate result of the Defendant's negligence, Plaintiff
has sustained severe and permanent injuries; has incurred pain and
suffering (past, present, and future); has endured mental anguish (past,
present and future); has incurred medical expense; has incurred loss of
wages; has incurred loss of earning capacity; and has sustained loss of
the enjoyment of life all to her detriment.
7. That the damages sustained by the Plaintiff are in excess of
the small claims jurisdictional amount and the Defendant is liable to her
for said damages.
WHEREFORE, Plaintiff, Christine Putnam, prays for judgment
against Defendant, City of Dubuque, in an amount which will fully,
fairly, and adequately compensate her for her loss, for legal interest
thereon, and for the costs of this action.
E
JAMES ROTH A 0006853
ROTH LAW OFFICE, P.C.
1400 University Avenue, Suite D
Dubuque, IA 52001
Telephone: (563) 557 -1611
Facsimile: (563) 557 -9775
Email: JRoth @rothlawdbq.com
ATTORNEY FOR PLAINTIFF