97-324.
Council File # � - 3 a �
� ��� "-' Green Sheet $ 31140
RESOLUTIOPI
SAINT PAUL, MINNESOTA � ��, �,; 1 , y
� :�:��'_
_ t..1 S e ` . i :_
Presented
Referred
Committee: Date
RESOLVED, that upon execution and delivery of a release, in fiill, to the City of
St. Paul, the proper City officers are hereby authorized and directed to pay out of the
Tort Liability Fund, 09070-0511, to Julie Donnelly and Hvass, Weisman & King, her
attorneys, the sum of $80,060.00 in full settlement of her claim for damages arising out
of a velucle-pedestrian accident at or near Summit Avenue and Macalester Street, in the
City of St. Paul on November 9, 1994.
Requested by Department of:
City Attorney
sy: i AisFI`C. �, �
Adopted by Council: Date 1"' „__ J„ °q �_ ,9.c�f�7 Form Approved by City Attorney
�_-,�-_,-x.-�- 1 /
Adoption Certified by Council Secretary gY: ��� �"►�,
C
BY��.�� a- - Approved by Mayor for Submission to
/ / Council
Approved by Mayor: Date `7(Z/
�/` ,, B ��
By: y � ���� Y:
�. � �-� �� � �
DEPARTMENT/OFFICE/COUNCIL DATEINITIATE� GREEN SHEE N� 31 140 '
Cit Attorne 3 18 97 — -
, CONTACT PEXSON S PHONE Q DEPAATMENT DIRECTORNITIAUDATE � CT' COUNCIL �NITIAVC/ATE
Theodore D. Leon 266-8747 A��N OCINARORNEY �CIIYCLEqK
MUST BE ON COUNCIL AGENDA BY (DATE) NUMBEq FON Q gUDGET DIRECTOR � PIN. & MGT. SERVICES DIR.
XOUIING
ORDER � MpyOR (OR ASSISTANn �
TOTAL # OF SIGNATURE PAGES (CLIP ALL LOCATIONS FOR SIGNATURE)
ACTION qEQUESTED: y �� �
Approval of resolution settling the claim against the City of St. Paul by 7ulie Do .
��� .19 19�7
RECOMMENDATIONS: Apprave (A) a Reject (R) pEBSONAL SERV�CE CONTqACTS MUST ANSWEH THE FOLLOWIN -� IeN9l
_ PLANNING COMMISSION _ CIVIL SERVICE CAMMISSION �� Has this person/Firm ever worketl untler a contrect for this departmeM� 3 i�'• � t%' ':�i
_CIBGOMMffTEE YES NO
_ S7AFF 2. Has tfiis personlfirm ever been a city employee?
— YES NO
_ DISTRiCT COURT — 3. Does this pef5on/FiRn pos5ess a skili not normally po55e5setl by any current city employee?
SUPPOPTSWHICHCOUNqLO&fEC57VE? VES NO
Erzplain all yas answers on seperate sheet and attach to green sheet
INITIATING PROBLEM. ISSUE, OPP�RTUNITY (Who, Whe1, When. Where, Why�:
On November 9, 1994, Plaintiff'7ulie Donnelly was a riventy year oid Macalester student who
was attempting to cross Summit Avenue in the crosswalk of an uncontrolled intersection. Public
Works employee James Zieba was eastbound on Smnmit and slammed on his brakes when he saw
Donnelly in the crosswatk. The sideview mirror on Zieba's truck hit plaintiff on the left temple
throwing her to the ground.
i' lo k in both directions before
Ao,�ANTA�ES � v uring into the crosswalk. However, at her deposition she claimed that she was stunned and
disoriented when talldng Co the officer and that her recollection was that she looked both directions,
then stepped offthe curb and waited for traffc to pass before continuing across when she was struck
by the Ciry vehicle. At the scene Zieba reported that plaintiff ran or darted out into the street. Later
Zieba testified that plaintiff simpiy watked into the crosswalk without looking in his direction.
Plaintiff was transported to the emergency room where a lacerarion on her head was closed with
stitches. She was dischazged and spent the ne�rt several days in bed. Within a week she had
DISADVANTAGE r� severe es ong wi a en aat ess, t sensi vi , an cu re mg an
concentrating. PLvrrtiffwas examined by a neurologist and had an EEG performed which was read
as abnormal and indicative of a brain dysfunction caused by trauma. Plaintiff also had an MRI of the
brain which showed two lesions which could have been caused by trauma.
--- ---- --Appro�mately s'vc months post accident Dr. Krasnow perFormed an independent medical
examination of plaintiff. Dr. Krasnow concluded that plaintiff was suffering from post-traumaric
DISAOVANT . �
Plaintiffcontinued to complain of cognirive difficulties and these complaints were confirmed
by her deteriorating perforn�ance at college and the necessity of hiring a reader and note taker to help
with her school work. Eventually, plaintiff returned to Massachusetts to live with her parents and
seek additional ueatment. She was seen by a number of specialists including a neuropsychologist
who did extensive testing and concluded that she had suffered a mild traumatic brain injury causing
TOTAL AMOUNT OF TRANSACTION S 8O , O OO , O O COST/REVEfJUE BUDGE7ED (CIRCLE ONE) Q NO
FUNDIH(iSOURCE Tort Liability qCSIV1SYNUMBER 09070
FINANCIAL INFORMATION: (EXPLAIN)
`� \\�O
°� 3Z�
cognitive deficits including impaired concentration and memory. Her neuropsychologist concluded
that plainti� a nationai merit scholar, would have extreme difficulty with further college level studies.
Plaintiffs expert concluded that her cunent condition was directly caused by the accident of
November 9. 1994.
The parties engaged in court ordered mediation on February 21, 1997. On that date the
parties agreed to a proposed settlement ofplaintiff's claims for a totai payment of $50,000.00 by the
City of St. Paul, which includes settlement of plaintiff's no-fault wage loss. The City also agrees to
pay reasonable medicai costs up to $20,000.00, as required under the no-fault act. Criven the liability
issues and, in particulaz, the nature and extem of plainti�s injuries, this office recommends settlement
of this matter in the amount of $80,000.00.
.
Council File # � - 3 a �
� ��� "-' Green Sheet $ 31140
RESOLUTIOPI
SAINT PAUL, MINNESOTA � ��, �,; 1 , y
� :�:��'_
_ t..1 S e ` . i :_
Presented
Referred
Committee: Date
RESOLVED, that upon execution and delivery of a release, in fiill, to the City of
St. Paul, the proper City officers are hereby authorized and directed to pay out of the
Tort Liability Fund, 09070-0511, to Julie Donnelly and Hvass, Weisman & King, her
attorneys, the sum of $80,060.00 in full settlement of her claim for damages arising out
of a velucle-pedestrian accident at or near Summit Avenue and Macalester Street, in the
City of St. Paul on November 9, 1994.
Requested by Department of:
City Attorney
sy: i AisFI`C. �, �
Adopted by Council: Date 1"' „__ J„ °q �_ ,9.c�f�7 Form Approved by City Attorney
�_-,�-_,-x.-�- 1 /
Adoption Certified by Council Secretary gY: ��� �"►�,
C
BY��.�� a- - Approved by Mayor for Submission to
/ / Council
Approved by Mayor: Date `7(Z/
�/` ,, B ��
By: y � ���� Y:
�. � �-� �� � �
DEPARTMENT/OFFICE/COUNCIL DATEINITIATE� GREEN SHEE N� 31 140 '
Cit Attorne 3 18 97 — -
, CONTACT PEXSON S PHONE Q DEPAATMENT DIRECTORNITIAUDATE � CT' COUNCIL �NITIAVC/ATE
Theodore D. Leon 266-8747 A��N OCINARORNEY �CIIYCLEqK
MUST BE ON COUNCIL AGENDA BY (DATE) NUMBEq FON Q gUDGET DIRECTOR � PIN. & MGT. SERVICES DIR.
XOUIING
ORDER � MpyOR (OR ASSISTANn �
TOTAL # OF SIGNATURE PAGES (CLIP ALL LOCATIONS FOR SIGNATURE)
ACTION qEQUESTED: y �� �
Approval of resolution settling the claim against the City of St. Paul by 7ulie Do .
��� .19 19�7
RECOMMENDATIONS: Apprave (A) a Reject (R) pEBSONAL SERV�CE CONTqACTS MUST ANSWEH THE FOLLOWIN -� IeN9l
_ PLANNING COMMISSION _ CIVIL SERVICE CAMMISSION �� Has this person/Firm ever worketl untler a contrect for this departmeM� 3 i�'• � t%' ':�i
_CIBGOMMffTEE YES NO
_ S7AFF 2. Has tfiis personlfirm ever been a city employee?
— YES NO
_ DISTRiCT COURT — 3. Does this pef5on/FiRn pos5ess a skili not normally po55e5setl by any current city employee?
SUPPOPTSWHICHCOUNqLO&fEC57VE? VES NO
Erzplain all yas answers on seperate sheet and attach to green sheet
INITIATING PROBLEM. ISSUE, OPP�RTUNITY (Who, Whe1, When. Where, Why�:
On November 9, 1994, Plaintiff'7ulie Donnelly was a riventy year oid Macalester student who
was attempting to cross Summit Avenue in the crosswalk of an uncontrolled intersection. Public
Works employee James Zieba was eastbound on Smnmit and slammed on his brakes when he saw
Donnelly in the crosswatk. The sideview mirror on Zieba's truck hit plaintiff on the left temple
throwing her to the ground.
i' lo k in both directions before
Ao,�ANTA�ES � v uring into the crosswalk. However, at her deposition she claimed that she was stunned and
disoriented when talldng Co the officer and that her recollection was that she looked both directions,
then stepped offthe curb and waited for traffc to pass before continuing across when she was struck
by the Ciry vehicle. At the scene Zieba reported that plaintiff ran or darted out into the street. Later
Zieba testified that plaintiff simpiy watked into the crosswalk without looking in his direction.
Plaintiff was transported to the emergency room where a lacerarion on her head was closed with
stitches. She was dischazged and spent the ne�rt several days in bed. Within a week she had
DISADVANTAGE r� severe es ong wi a en aat ess, t sensi vi , an cu re mg an
concentrating. PLvrrtiffwas examined by a neurologist and had an EEG performed which was read
as abnormal and indicative of a brain dysfunction caused by trauma. Plaintiff also had an MRI of the
brain which showed two lesions which could have been caused by trauma.
--- ---- --Appro�mately s'vc months post accident Dr. Krasnow perFormed an independent medical
examination of plaintiff. Dr. Krasnow concluded that plaintiff was suffering from post-traumaric
DISAOVANT . �
Plaintiffcontinued to complain of cognirive difficulties and these complaints were confirmed
by her deteriorating perforn�ance at college and the necessity of hiring a reader and note taker to help
with her school work. Eventually, plaintiff returned to Massachusetts to live with her parents and
seek additional ueatment. She was seen by a number of specialists including a neuropsychologist
who did extensive testing and concluded that she had suffered a mild traumatic brain injury causing
TOTAL AMOUNT OF TRANSACTION S 8O , O OO , O O COST/REVEfJUE BUDGE7ED (CIRCLE ONE) Q NO
FUNDIH(iSOURCE Tort Liability qCSIV1SYNUMBER 09070
FINANCIAL INFORMATION: (EXPLAIN)
`� \\�O
°� 3Z�
cognitive deficits including impaired concentration and memory. Her neuropsychologist concluded
that plainti� a nationai merit scholar, would have extreme difficulty with further college level studies.
Plaintiffs expert concluded that her cunent condition was directly caused by the accident of
November 9. 1994.
The parties engaged in court ordered mediation on February 21, 1997. On that date the
parties agreed to a proposed settlement ofplaintiff's claims for a totai payment of $50,000.00 by the
City of St. Paul, which includes settlement of plaintiff's no-fault wage loss. The City also agrees to
pay reasonable medicai costs up to $20,000.00, as required under the no-fault act. Criven the liability
issues and, in particulaz, the nature and extem of plainti�s injuries, this office recommends settlement
of this matter in the amount of $80,000.00.
.
Council File # � - 3 a �
� ��� "-' Green Sheet $ 31140
RESOLUTIOPI
SAINT PAUL, MINNESOTA � ��, �,; 1 , y
� :�:��'_
_ t..1 S e ` . i :_
Presented
Referred
Committee: Date
RESOLVED, that upon execution and delivery of a release, in fiill, to the City of
St. Paul, the proper City officers are hereby authorized and directed to pay out of the
Tort Liability Fund, 09070-0511, to Julie Donnelly and Hvass, Weisman & King, her
attorneys, the sum of $80,060.00 in full settlement of her claim for damages arising out
of a velucle-pedestrian accident at or near Summit Avenue and Macalester Street, in the
City of St. Paul on November 9, 1994.
Requested by Department of:
City Attorney
sy: i AisFI`C. �, �
Adopted by Council: Date 1"' „__ J„ °q �_ ,9.c�f�7 Form Approved by City Attorney
�_-,�-_,-x.-�- 1 /
Adoption Certified by Council Secretary gY: ��� �"►�,
C
BY��.�� a- - Approved by Mayor for Submission to
/ / Council
Approved by Mayor: Date `7(Z/
�/` ,, B ��
By: y � ���� Y:
�. � �-� �� � �
DEPARTMENT/OFFICE/COUNCIL DATEINITIATE� GREEN SHEE N� 31 140 '
Cit Attorne 3 18 97 — -
, CONTACT PEXSON S PHONE Q DEPAATMENT DIRECTORNITIAUDATE � CT' COUNCIL �NITIAVC/ATE
Theodore D. Leon 266-8747 A��N OCINARORNEY �CIIYCLEqK
MUST BE ON COUNCIL AGENDA BY (DATE) NUMBEq FON Q gUDGET DIRECTOR � PIN. & MGT. SERVICES DIR.
XOUIING
ORDER � MpyOR (OR ASSISTANn �
TOTAL # OF SIGNATURE PAGES (CLIP ALL LOCATIONS FOR SIGNATURE)
ACTION qEQUESTED: y �� �
Approval of resolution settling the claim against the City of St. Paul by 7ulie Do .
��� .19 19�7
RECOMMENDATIONS: Apprave (A) a Reject (R) pEBSONAL SERV�CE CONTqACTS MUST ANSWEH THE FOLLOWIN -� IeN9l
_ PLANNING COMMISSION _ CIVIL SERVICE CAMMISSION �� Has this person/Firm ever worketl untler a contrect for this departmeM� 3 i�'• � t%' ':�i
_CIBGOMMffTEE YES NO
_ S7AFF 2. Has tfiis personlfirm ever been a city employee?
— YES NO
_ DISTRiCT COURT — 3. Does this pef5on/FiRn pos5ess a skili not normally po55e5setl by any current city employee?
SUPPOPTSWHICHCOUNqLO&fEC57VE? VES NO
Erzplain all yas answers on seperate sheet and attach to green sheet
INITIATING PROBLEM. ISSUE, OPP�RTUNITY (Who, Whe1, When. Where, Why�:
On November 9, 1994, Plaintiff'7ulie Donnelly was a riventy year oid Macalester student who
was attempting to cross Summit Avenue in the crosswalk of an uncontrolled intersection. Public
Works employee James Zieba was eastbound on Smnmit and slammed on his brakes when he saw
Donnelly in the crosswatk. The sideview mirror on Zieba's truck hit plaintiff on the left temple
throwing her to the ground.
i' lo k in both directions before
Ao,�ANTA�ES � v uring into the crosswalk. However, at her deposition she claimed that she was stunned and
disoriented when talldng Co the officer and that her recollection was that she looked both directions,
then stepped offthe curb and waited for traffc to pass before continuing across when she was struck
by the Ciry vehicle. At the scene Zieba reported that plaintiff ran or darted out into the street. Later
Zieba testified that plaintiff simpiy watked into the crosswalk without looking in his direction.
Plaintiff was transported to the emergency room where a lacerarion on her head was closed with
stitches. She was dischazged and spent the ne�rt several days in bed. Within a week she had
DISADVANTAGE r� severe es ong wi a en aat ess, t sensi vi , an cu re mg an
concentrating. PLvrrtiffwas examined by a neurologist and had an EEG performed which was read
as abnormal and indicative of a brain dysfunction caused by trauma. Plaintiff also had an MRI of the
brain which showed two lesions which could have been caused by trauma.
--- ---- --Appro�mately s'vc months post accident Dr. Krasnow perFormed an independent medical
examination of plaintiff. Dr. Krasnow concluded that plaintiff was suffering from post-traumaric
DISAOVANT . �
Plaintiffcontinued to complain of cognirive difficulties and these complaints were confirmed
by her deteriorating perforn�ance at college and the necessity of hiring a reader and note taker to help
with her school work. Eventually, plaintiff returned to Massachusetts to live with her parents and
seek additional ueatment. She was seen by a number of specialists including a neuropsychologist
who did extensive testing and concluded that she had suffered a mild traumatic brain injury causing
TOTAL AMOUNT OF TRANSACTION S 8O , O OO , O O COST/REVEfJUE BUDGE7ED (CIRCLE ONE) Q NO
FUNDIH(iSOURCE Tort Liability qCSIV1SYNUMBER 09070
FINANCIAL INFORMATION: (EXPLAIN)
`� \\�O
°� 3Z�
cognitive deficits including impaired concentration and memory. Her neuropsychologist concluded
that plainti� a nationai merit scholar, would have extreme difficulty with further college level studies.
Plaintiffs expert concluded that her cunent condition was directly caused by the accident of
November 9. 1994.
The parties engaged in court ordered mediation on February 21, 1997. On that date the
parties agreed to a proposed settlement ofplaintiff's claims for a totai payment of $50,000.00 by the
City of St. Paul, which includes settlement of plaintiff's no-fault wage loss. The City also agrees to
pay reasonable medicai costs up to $20,000.00, as required under the no-fault act. Criven the liability
issues and, in particulaz, the nature and extem of plainti�s injuries, this office recommends settlement
of this matter in the amount of $80,000.00.