151014 LT St Paul Clerk with notice of rep, notice of claim, Argenti.pdf Michael Healey Law, LLC
Michael B. Healey, Esq.
Michael Healey Law, LLC
Heritage Rose Building
1599 Selby Avenue, Ste. 106LL, St. Paul, MN 55104
mikeh@michaelhealeylaw.com
Tel: 651-699-4030
Fax: 651-331-7001
October 14, 2015
City of St. Paul
Ms. Sandra Bodensteiner
Manager, Tort Liability
310 City Hall
15 Kellogg Blvd., West
Saint Paul, MN 55102
Re: Notice of Representation, Notice of Claim,
Injury to Ms. Deborah Argenti at Como Park Zoo and Conservatory
DOI: 10/02/15
Ms. Bodensteiner,
I wish to inform you that I will represent Ms. Deborah Argenti for the injury she suffered
when a grossly uneven sidewalk at the entryway at the Como Park Zoo and Conservatory
caused her to fall on October 2, 2015 at which time Ms. Argenti suffered a fractured hip
and was taken from the premises by way of ambulance.
I understood from your staff in a phone call today that you are the City of St. Paul’s
representative for insurance claims made for injuries suffered at Como Park Zoo. If you
could confirm that at my email below, I would greatly appreciate it. If there is any other
information you require related to a notice of this claim, please let me know.
I will provide further details including medical records and photos of the sidewalk and
Ms. Argenti’s injuries with a request for settlement of this matter in the very near future.
Regards,
/s/Michael B. Healey, Esq.
C. Client