Conners, Ryan - Rockstar AutoNOTICE OF CLAIM FORM to the City of Saint Paul, Minnesota
Minnesota State Statute 466.05 states that “…every person…who claims damages from any municipality…shall cause to be presented to the governing body of the
municipality within 180 days after the alleged loss or injury is discovered a notice stating the time, place, and circumstances thereof, and the amount of compensation
or other relief demanded.”
Please complete this form in its entirety by clearly typing or printing your answers to each question. If you have additional documentation you may add those
documents to your submission. You will not be contacted by telephone unless clarification is needed. The claim process for investigations can take upwards of
four (4) weeks. This form must be signed, dated with all applicable sections completed. Submission is to the Saint Paul City Clerk’s Office. You may email, fax
(651-266-8574) or mail the form. Mailing address is “Saint Paul City Clerk, 15 West Kellogg Blvd., Suite 310, Saint Paul, MN 55102”
Individuals: First Name __Ryan_______________________ Last Name __Conners______________________________________
Please Indicate Your Pronouns: She/ Her/Hers ☐ He/Him/His ☒_ They/ Them/Theirs ☐
Company or Business Name: _Leland Conners PLC__________________________________________________________________
Is this claim being made by an Insurance Company? NO If yes, what is your Claim/File Number?: _____________________
Is this claim being made by an Attorney? YES If yes, what is your File Number? _395313______________________________
If yes, then provide your Insured’s/ Client’s Name __Rockstar Auto__________________________________________________
Street Address: __60 South Sixth Street, Suite 2800_______________________________________________________________
City: __Minneapolis___________________________________ State _MN_______________ Zip Code _55402______________
Daytime/Work Phone _612-255-2255_______________________ Cell Phone __________________________________________
Date of Incident or Date Discovered (Must complete) 10/12/2021 Time _2:00pm________________________
Please state, in detail, what happened that prompted you to file a Notice of Claim Form. _ The incident started after Rockstar had
repossessed a 2015 Dodge Charger (the “Vehicle”) it owns from an individual who had failed to make required payments on the
Vehicle. The repossession was legitimate and within Rockstar’s contractual and legal rights. When the repo man arrived at the
Premises with the repossessed Vehicle, immediately another vehicle with a woman pulled into the lot and entered the Vehicle. She
refused to get out of the Vehicle or leave.
Within minutes, two additional cars carrying five women and one man arrived at the Premises. The individuals got out of their
vehicles and started threatening Rockstar employees and personnel, and being extremel y unruly. Rockstar therefore called the St.
Paul Police to the Premises. Three police vehicles arrived at the lot, with two female officers and one male officer. The ma le police
officer tried to convince the unruly individuals to leave the Premises; but t hey were loud, disrespectful, and threatening, and refused
to leave. Although the officers remained on the scene, they did not act to prevent the unruly individuals from any conduct. F or
several hours, it was chaos, and the women who were standing outside the repossessed Vehicle were shouting, cursing, and
threatening, while the police officers just stood there watching.
Then, shockingly, one of the officers verbally authorized the individuals to damage the Vehicle. The officer ordered the indi viduals to
do up to “$8,000 in damage” to the Vehicle. Rockstar’s manager asked the officer what authority she had to verbally authorize and
allow them to inflict physical damage to the Vehicle. The officer’s response was shocking: they could do whatever they want ed to do
to the Vehicle simply because they had made a down payment in the past.
Rockstar’s employees all watched helplessly while the women tore the Vehicle apart with knives and scissors, put liquid deter gent in
the gas tank and in the engine, cut all the cables, and essentially destroyed the Vehicle—all while 3 police officers stood and guarded
them and encouraged the damage. At one point, one of the women also pointed a pair of scissors an inch away from a Rockstar
employee to make him to move away from the Vehicle. Again, the officers watched and did nothing._______________________
Please state why or how you feel the City of Saint Paul is responsible for your Damages? _St. Paul Police officers stood by and did
nothing as multiple individuals damaged the Vehicle._____________________________
Please check the reason that most closely describes the reason for your submitting a claim. Please note the documents that will
need to be provided with your completed form. Photographs will be accepted. All documents submitted become the property of
the City of Saint Paul and shall not be returned.
☐ Automobile damage from a motor vehicle accident: please provide two estimates for repairs or actual bill that has been paid.
☐ Automobile damage from a street defect or pothole : please provide two estimates for repairs or actual bill that has been pai d.
☐ Automobile was towed and may or may not have sustained damage: please provide copy of towing ticket (if available), receipt
from Impound Lot, and two estimates for repairs or actual bill that has been paid.
☐ Snow Emergency: please provide copy of towing ticket (if available), receipt from Impound Lot, and two estimates for repairs or
actual bill that has been paid.
☒ Property damage: please provide two estimates for repairs or actual bill that has been paid.
☐ You were injured during a motor vehicle accident: please provide police report number, details about injury.
☐ You were injured in the City of Saint Paul: please provide police report number, witnesses and details about injury.
This section must be completed for all claims.
Is there a police report for this incident? YES If yes, please provide the police report case number _21-213-806________________
Revised December 2021
If yes, what law enforcement agency responded? _St. Paul Police___________________________________________________
Where did the incident take place? Please provide a street address, intersection or name of City park or facility.
__1205 University Ave. W., St. Paul, MN 55104____________________________________________________________________
Notice of Claim Form, page two. Failure to complete and return both pages will result in delays.
What would you like to see happen to resolve this claim to your satisfaction? _Rockstar would like the value of the vehicle______
Were there witnesses to this incident? Please provide names and contact phone numbers. _Derek Gull Towing: 763-267-3671;
Michael Carter: 651-890-6840; Salman Musani: 651-447-1998_____________________________
For property damage claims, including vehicle accidents.
Your vehicle’s information: Year _2015__ Make _Dodge__________ Model _Charger SXT___________ Color _Purple wrap_____
License Plate # _____________________ State vehicle is registered in _MN_____________________
Registered owner of vehicle ______________________________ Driver ______________________________________
Area(s) damaged _Many, including engine, transmission, body, and interior________________________
If a City vehicle was involved: License Plate # _______________________________ Color _______________________________
Was there City insignia on the vehicle? Yes No Driver’s Name _____________________________________________
Other property damaged: ___________________________________________________________________________________
For injury claims of any type.
What part of your body was injured? __________________________________________________________________________
Did you go to the emergency room or urgent care? Yes No Where? _________________________________________________
Was medical treatment received? Yes No Where? ______________________________________________________________
First day of medical treatment? _____________ Are you still receiving medical treatment? Yes No
Did you miss any work as result of this incident? Yes No Employer(s) _______________________________________________
How much time have you missed from work?___________________________________________________________________
If you are submitting other documents, please state what you are attaching and how many pages. Photographs of repossession
order, damage to vehicle, and Officer Mahon’s card with case number; also 2 estimates for repairs. 11 pages
148 Osborne Rd NE
Fridley, MN 55432
96033-1
Estimator:
Email:
DON @BOHN
andy@maacofridley.com
Store #M2342
rockstar auto
,
Phone 1 (651) 528-7865
15 Dodge Charger Police 4 DR Sedan
Lic:
Mileage In:
#MAACOVER www.maaco.com
Maaco Collision Repair & Auto Painting Centers are Licensed by Maaco Franchising, Inc, and are privately owned and operated
Phone 2
Phone 3
Phone # (763) 572-2222
Fax # (763) 572-3886
15 Dodge Charger Police 4 DR Sedan
ESTIMATE
Email SALMANMUSANII@GMAIL.COM
Estimated:2/1/2022
Paint Code :PX8, X5X9
sal
rockstar auto
VIN:Color:BLACK2C3CDXAT0FH862825
Operation Description Type Part #Code Qty Amount Units Spot
Refinish Price
Remove/Install Panel,Frt Bmpr License Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install Grille Assembly Other R&I ASSEMBLY 1.40 86.80BL
Repair Cover,Front End Other REPAIR 3.00 186.00BL
Refinish Cover,Front End Other Refinish 5.50 341.00
Remove/Install Front End Cover O/H Other R&I ASSEMBLY 1.50 93.00BL
Remove/Install Front End Cover R & I Other R&I ASSEMBLY
Remove/Install Headlamp Assy,Halogen LT Other R&I ASSEMBLY 0.30 18.60BL
Remove/Install Headlamp Assy,Halogen RT Other R&I ASSEMBLY 0.30 18.60BL
Repair Panel,Hood Other REPAIR 3.00 186.00BL
Refinish Panel,Hood Other Refinish 3.70 229.40
Remove/Install Nozzle,W/S Washer LT Other R&I ASSEMBLY 0.10 6.20BL
Remove/Install Nozzle,W/S Washer RT Other R&I ASSEMBLY 0.10 6.20BL
Repair Fender,Front LT Other REPAIR 3.00 186.00BL
Refinish Fender,Front LT Other Refinish 2.50 155.00
Repair Fender,Front RT Other REPAIR 3.00 186.00BL
Refinish Fender,Front RT Other Refinish 2.50 155.00
Remove/Install Skirt,Inner Fender LT Other R&I ASSEMBLY 0.60 37.20BL
Remove/Install Skirt,Inner Fender RT Other R&I ASSEMBLY 0.60 37.20BL
Remove/Replace Battery New BA94R765AA TP 1.00 $230.00 0.40 64.00ML
Repair Panel,Bodyside Front LT Other REPAIR 5.00 310.00BL
Refinish Panel,Bodyside Front LT Other Refinish 3.80 235.60
Repair Panel,Bodyside Front RT Other REPAIR 2.00 124.00BL
Refinish Panel,Bodyside Front RT Other Refinish 3.80 235.60
Remove/Replace Outlet,Air Vent Duct LT New 1VM61DX9AB TP 1.00 $160.00 0.10 6.20BL
Remove/Replace Outlet,Air Vent Duct RT New 1VM62DX9AB TP 1.00 $135.00 0.10 6.20BL
Remove/Replace Control Unit,A/C-HEATE New 5064630AI TP 1.00 $1215.00 0.70 112.00ML
Remove/Replace Airbag,Steering Wheel New 1ZZ44DX9AH TP 1.00 $1035.00 0.30 48.00ML
Repair Door Shell,Front LT Other REPAIR 3.00 186.00BL
Refinish Door Shell,Front LT Other Refinish 2.60 161.20
Repair Door Shell,Front RT Other REPAIR 3.00 186.00BL
Refinish Door Shell,Front RT Other Refinish 2.30 142.60
At Maaco, we value your opinion. Please visit www.TellMaaco.com to tell us about your experience.
Date: 2/1/2022 Time: 10:41 AM Page 1 of 3
ESTIMATE 96033-1
Remove/Install W/Strip,Frt Door Lwr LT Other R&I ASSEMBLY 0.50 31.00BL
Remove/Install W/Strip,Frt Door Lwr RT Other R&I ASSEMBLY 0.50 31.00BL
Remove/Install W/Strip,Front Door LT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install W/Strip,Front Door RT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install W/Strip,Belt Outer LT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install W/Strip,Belt Outer RT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install Pnl,Inner Door Trim LT Other R&I ASSEMBLY
Remove/Install Pnl,Inner Door Trim RT Other R&I ASSEMBLY
Remove/Install Mirror,Outer R/C LT Other R&I ASSEMBLY 0.90 55.80BL
Remove/Install Mirror,Outer R/C RT Other R&I ASSEMBLY 0.80 49.60BL
Remove/Install Handle,Front Door Otr LT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Replace Handle,Front Door Inr LT New 1RE71DX9AF TP 1.00 $240.00 0.10 6.20BL
Remove/Install Handle,Front Door Otr RT Other R&I ASSEMBLY 0.20 12.40BL
Repair Door Shell,Rear LT Other REPAIR 3.00 186.00BL
Refinish Door Shell,Rear LT Other Refinish 2.00 124.00
Repair Door Shell,Rear RT Other REPAIR
Refinish Door Shell,Rear RT Other Refinish 2.00 124.00
Remove/Install W/Strip,Rear Door LT Other R&I ASSEMBLY 0.10 6.20BL
Remove/Install W/Strip,Rear Door RT Other R&I ASSEMBLY 0.10 6.20BL
Remove/Install W/Strip,RR Door Lower LT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install W/Strip,RR Door Lower RT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install W/Strip,Belt Outer LT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install W/Strip,Belt Outer RT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install Pnl,Inner Door Trim LT Other R&I ASSEMBLY 0.40 24.80BL
Remove/Install Pnl,Inner Door Trim RT Other R&I ASSEMBLY 0.40 24.80BL
Remove/Install Handle,RR Door Outer LT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install Supt,RR Door Handle LT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install Handle,RR Door Outer RT Other R&I ASSEMBLY 0.20 12.40BL
Remove/Install Supt,RR Door Handle RT Other R&I ASSEMBLY 0.20 12.40BL
Repair Panel,Roof Other REPAIR 3.00 186.00BL
Refinish Panel,Roof Other Refinish 3.30 204.60
Repair Panel,Quarter LT Other REPAIR 3.00 186.00BL
Refinish Panel,Quarter LT Other Refinish 2.20 136.40
Repair Panel,Quarter RT Other REPAIR 3.00 186.00BL
Refinish Panel,Quarter RT Other Refinish 2.20 136.40
Repair Door,Fuel Filler LT Other REPAIR 0.50 31.00BL
Refinish Door,Fuel Filler LT Other Refinish 0.30 18.60
Remove/Install Door,Fuel Filler LT Other R&I ASSEMBLY 0.30 18.60BL
Remove/Install Shield,Quarter Inner LT Other R&I ASSEMBLY 0.50 31.00BL
Remove/Install Shield,Quarter Inner RT Other R&I ASSEMBLY 0.30 18.60BL
Repair Lid,Rear Deck Other REPAIR 5.00 310.00BL
Refinish Lid,Rear Deck Other Refinish 2.30 142.60
Remove/Install Pnl,Lid Inner Trim Other R&I ASSEMBLY
Remove/Install N/Plate,Deck Lid Other R&I ASSEMBLY 0.20 12.40
Remove/Replace N/Plate,Deck Lid New 68216156AB TP 1.00 $54.10 0.20 12.40
Remove/Install Cyl,Deck Lid Lock Other R&I ASSEMBLY 0.10 6.20BL
Remove/Install Camera,Deck Lid Other R&I ASSEMBLY 0.70 43.40BL
Remove/Install Taillamp Assembly,Otr LT Other R&I ASSEMBLY
Remove/Install Taillamp Assembly,Otr RT Other R&I ASSEMBLY
Remove/Install Taillamp Assembly,Inr Other R&I ASSEMBLY 0.30 18.60BL
Remove/Install Lamp,License Other R&I ASSEMBLY
Remove/Install RR Bumper Cvr Overhaul Other R&I ASSEMBLY 3.20 198.40BL
Repair Cover,Rear Bumper Other REPAIR 5.00 310.00BL
Refinish Cover,Rear Bumper Other Refinish 3.20 198.40
Sublet Hazardous Waste Sublet Sublet HW 1.00 $5.00
Remove/Replace Car Cover AfterMarket AfterMarket PM 1.00 $7.50 0.20 12.40
Date: 2/1/2022 Time: 10:41 AM Page 2 of 3
ESTIMATE 96033-1
Remove/Replace Corrosion Protection AfterMarket AfterMarket PM 1.00 $7.50 0.30 18.60
Remove/Replace Flex Additive AfterMarket AfterMarket TP 1.00 $5.00
Sublet PRE-SCAN Sublet Sublet NS 1.00 $149.95 0.50 80.00ML
Sublet POST-SCAN Sublet Sublet NS 1.00 $149.95 0.50 80.00ML
Repair Color Sand & Buff Other Other 1.00 62.00BL
Repair NO WARRANTY ON RUST Other Other
Repair remove wrap Other Other 10.00 620.00BL
Repair additional paint correctio Other Other 15.00 930.00BL
Sublet complete detail Sublet Sublet NS 1.00 $499.95
Repair disable air bags Other Other 0.50 80.00ML
Sublet under hood issues Sublet Sublet NS 1.00 $750.00
Note: possibil lots mo=re
Sublet rewrap vehicle Sublet Sublet NS 1.00 $4500.00
Paint Materials PM 1.00 $1768.00
Remarks **CUSTOMER IS RESPONSIBLE FOR FULLY UNDERSTANDING THIS ESTIMATE AND WHAT WORK IS TO BE
COMPLETED OR NOT COMPLETED.
Maaco recommends the use of OEM parts for replacement parts. Aftermarket, used, or recycled parts may not look right or
fit correctlyl as OEM parts provided by the manufacturer.
Parts must be paid upfront before work is started. This shop generally does not accept customer provided parts, if we do
take them, Maaco has NO WARRANTY on any work on those parts.
Maaco is not responsible for parts/trim that may break upon removal from vehicles, these are fragile parts and we try to
remove and install carefully but if they break they will need to be replaced at a cost to the customer.
No other Body Work Wanted then stated on work order
Possible overspray may occur
Minor Imperfections will Show
Dirt nibs may be visable
No Guarantee on Rust
Wet Sand & Polish, Denib & Polish NOT provided unless noted on estimate
Trim Removal provides Maaco's Limited Lifetime Warranty
Any areas masked off are covered by a Maaco's Prorated warranty
1 Year Full
2 Year prorated
We accept cash and credit cards, NO PERSONAL CHECKS will be accepted.
Item Description Code Qty Each Price Total
Paint Refinish Labor RL 45.10 $62.00 $2796.20 $2796.20
Supplies-Paint Paint Materials PM $0.00 $1783.00 $1783.00
Body Shop Body Labor BL 90.80 $62.00 $5629.60 $5629.60
Mechanical Labor ML 2.90 $160.00 $464.00 $464.00
Parts Taxable Part TP $0.00 $3074.10 $3074.10
Sublet NonTaxable Sublet NS $0.00 $6049.85 $6049.85
Hazardous Waste Removal HW $0.00 $5.00 $5.00
$19801.75 $19801.75
$346.07 $346.07
$20147.82 $20147.82
Subtotal
Sales Tax
Estimate Total
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Date: 2/1/2022 Time: 10:41 AM Page 3 of 3