Nelson, Thomas Christopher Zipko
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871 East Seventh Street
JJ! � ! St. Paul, MN 55106
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July 9, 2012 VIA U.S. MAIL
Saint Paul City Clerk
310 City Hall
15 West Kellogg Boulevard,
Saint Paul, MN 55102
Re: Thomas Ben1amin Nelson v. City of St. Paul et al
Date of Assault: January 10'h, 2012
Place of Assault: 776 Aurora Avenue, City of St. Paul
NOTICE OF CLAIM PURSUANT TO M.S.A. & 466.05, SUBD. 1.
Dear City Clerk:
This office has been retained by Mr. Thomas Nelson who was assaulted and injured on
January l Oth, 2012 by three officers of the St. Paul Police Department when they used
excessive force in their arrest and apprehension of Mr. Nelson.
Our client, who was unarmed was assaulted by three undercover St. Paul Police
Officers who were investigating him for a possible gross misdemeanor crime. According
to police reports and witness statements Mr. Nelson was approached by the
undercover officers while he was on foot near the area of University and Avon avenues
in the City of St. Paul.
The officers appeared to have failed to identify who they were as they began a pursuit
of �Ar. Ns!sc�. Mr. Nelson, f�aring fcr his safety, eve�tually fled on foot and ran to his �
family member's aparfment at 776 Aurora Avenue. It was at this point that the officers
physically assaulted our client and used excessive force in their apprehension of Mr.
Nelson.
The officers assaulted Mr. Nelson with their fists, feet and a flashlight thereby causing a
number of injuries including a skull fracture, a fractured nose and fractured eye socket.
The excessive use of force and assault by the officers occurred inside a residence
where it was witnessed by at least 4 witnesses, including 2 juveniles.
As a result of his injuries Mr. Nelson was subsequently taken to Regions Hospital where he
remained for several weeks.
To that end, Mr. Nelson is seeking damages for in excess of $100,000.00 including but
not limited to his medical expenses.
Pa�;e l
Sincer ,
Ch ' er . Zipk
torney at L
Cc: Ms. Sarah Grewing
Ms. Cathy Lantry, St. Paul City Council President
Client
File
AFFIDAVIT OF SERVICE BY U.S. MAIL
STATE OF MINNESOTA )
) ss.
COUNTY OF RAMSEY )
I, Christopher J. Zipko, being duly sworn on oath says he served the following
documents:
1. Notice of Claim Pursuant to Minn. Stat. § 466.05 Subd.l
Upon the St. Paul City Clerk; Ms. Sarah Grewing, St. Paul City Attorney; and Ms. Cathy
Lantry, St. Paul City Council President, a true and correct copy thereof, on the 9th day of July,
2012,by serving the preceding documents by U.S. Mail to the following address:
St. Paul City Clerk
310 City Hall
15 West Kellogg Boulevard
Saint Paul,MN 55102
Ms. Sarah Grewing
St. Paul City Attorney
Room 400
15 West Kellogg Blvd
St. Paul, MN 55102
Ms. Cathy Lantry
St. Paul City Council President
320-C City Hall
15 West Kellogg Blvd
St. Paul, MN 55012
Subscribed and sworn to before me
this�day of ,2012.
C ' o er J. Z' o
� �
Notary Public
DENISE D. ROTH
Notary PubOo-�Akr�seota
' Mr camma.�on F�pY...an s��Qota