Phan (2) REC�lel��
NEWqUIST HE$RIGg Sc KIMBALL �OV O4 ZO�3
LAW OFFIGES, P.G. CITY CLERK
SUITE 301,FRIDLEY PLAZA OFFICE BUILDING
6401 UNIVERS;TY AVENUE N.E.
ATTORNEYS AT LAW FRIDLEY, MINNESOTA 55432-4381 PARALEGAL
CARL J. NEWQUIST PATRICIA A. PHILLIPS
TELEPHONE (763>571-6870
GREGG V. HERRICK
FAX(763)571-6884
SARAH M. KIMBALL
October 31, 2013
Saint Paui City Clerk
15 West Kellogg Boulevard
310 City Hall
Saint Paul, Minnesota 55102
Re: My Client: Huong Phan
Date of Loss: March 29, 2013
Time of Loss: Approximately 5:31 a.m.
Location of Loss: University Avenue at Raymond, City of St. Paul
Dear Sir or Madam:
I represent the above-noted Huong Phan in his claim for damages arising out of a
motor vehicle accident that occurred on or about March 29, 2013, at the controlled
intersection of University Avenue and Raymond in the City of Saint Paul.
On that early morning, Mr. Phan was proceeding south on Raymond into its
intersection with University Avenue on a green semaphore. Mr. Phan was driving to his
place of employment. Saint Paul Police Reserve Officer Lawrence Emil Langlois
proceeded ini� i'r�e ii�t�r�ectiur� agaii�st � r�u ��ght an� dt � ►�igh rat� of speed. Res����
Officer Langlois was driving a reserve police squad car and there were no emergency
lights or siren emanating from the squad car.
Reserve Officer Langlois struck my client's Volvo broadside, causing the vehicle to
roll over and come to rest on its hood. Mr. Phan's vehicle was towed from the scene and
was damaged beyond repair.
Sergeant Thomas Olson of the Saint Paul Police De�artment was one of the police
officers summoned to the scene and who likely prepared an incident report and a state
accident report. It is likely that Sergeant Olson or other Saint Paul Police officers took
statements from both Officer Langlois and other third parties.
Saint Paul City Clerk
October 31, 2013
Page 2 of 2
Mr. Phan was transported from the scene of the accident by ambulance to United
Hospital displaying immediate symptoms of concussion and other injuries.
Injuries Mr. Phan sustained in the accident include injuries to his head and brain,
injury to his lung, injuries to his neck and left shoulder, injury to ribs including contusion of
left chest, hand contusions and swelling, rectal bleeding, upper spine injury, tingling and
numbness in his left hand, balance problems, sense of pressure on the top of his head,
con�idera�,le pain ar�c� stifFness on the ieft side of his b�dy at all times whether lying down,
sitting, bending, walking, et cetera. The pain was such that Mr. Phan had difficulty
sleeping, he was disabled from performing his employment duties, and he remains under
treatment and partially disabled.
The City of Saint Paul had actual notice of both the accident and the injuries to
Mr. Phan. He did receive a phone message from someone employed by the City of Saint
Paul shortly after the accident, but he was so disabled and in pain that he did not respond.
Please consider this written notice to be compliant with statutory notice to a municipality of
an existing claim. Please have someone from the City of Saint Paul civil claims
department contact me with a claim number. My information is that the Saint Paul reserve
police officer admitted that he ran a red light which was confirmed by witnesses. I assume
that liability will be admitted, and that the City will fairly compensate Mr. Phan for the
injuries, pain and suffering he has sustained.
Thank you.
Very t�uly yours,
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