97-67�����E�;���
Presented By
Referred To
1
2
3
4
5
6
7
8
Council File � \� `�'�
Green Sheet # 3113�
RESOLVED, that upon execution and delivery of a release, in full, to the City of
St. Paul, the proper City officers are hereby authorized and directed to pay out of the
Tort Liability Fund, 0907-0511, to Patricia McBeath and Stuart McBeath and Sieben,
Polk, Laverdiere, Jones & Hawn, their attorneys, the sum of $17,500.00 in full settlement
of their claims for damages arising out of a motor vehicle accident with a city vehicle at
or near Leacington Avenue and University Avenue on July 21, 1994.
Requested by Department of:
City Attorne
By:
Approved by Mayor: Date
s /� (G ��rGL�
By: (l.;.r�--�— .!j . i--a-�--..
Form Approved by City Attorney
$ � � . ,--�......
Ar� oved by Mayor for Submission to
Council
By: ' " �- � C�'�^"'�J
RESOLUTION
CITY OF SAINT PAUL, MINNESOTA �
Adopted by Council: Date� ,��\qq�
Adoption Certified by Counc'1 Secretary
qZ bZ
DEPARTMENT/OFFICE/COUNCIL DATE INRIATED O
c�t Attorney Ol/14/97 GREEN SHEE N_ 31 138
CANTACTPERSONBPMONE ODEPqRTMENTDiRECfOR �CITYCOUNqL INITIAIJDATE
Theodore D. Leon, 266-8747 ���N �CITYATTORNEY �c
NUNBERFOR
MUSTBE ON CAUNCILAGENDA BV (DATE) ROUTING � BUIX'aET DIRECTOR � F
ORDEX � MqyOR (Ofl ASSIS O
TOTAL # OF SIGNATURE PAGES � (CLIP ALL LOCATIONS FOR SIGNATURE)
ACfIpN REQUESTED: �/ ��
1 f
Approval of resolution settling the claim against the City of
St. Paul by Patricia McBeath and Stuart McBeath for $17,500.00.
RECAMMENDATIONS: Mprove (A) ar Reject (R) PERSONAL SERVICE CONTRACTS MUST ANSWER TXE FOLLOWING �UESTIONS:
_ PLANNING CqMMISSiON . _ C4VIL SERVICE COMMISStON �� Has this person/firm e�er worketl under a contrac[ for this departmen[? �
_ q6 CoMMITfEE _ YES NO
_ STAFF 2: Has this person/firm ever been a city employee?
— YES NO
_ DIS7RIC7 COUR7 _ 3. Does this erson/Firm ossess a skill not normall
p p y possessed by any current ciry employee?
SUPPORTSWHICHCAUNqL�&IECTIVE? � YES NO
Explain all yes answers on separete sheet antl attach to green shcet
INITIATING PROBLEM. ISSUE, OPPORTUNITV (Who. Whet, When, Where. NTy):
On July 21, 1994, plaintiPf Patricia McBeath, a Yifty eight
year old woman, was stopped on southbound Lexington Avenue near
Aurora Avenue to make a U-Turn when she was rear-ended by an NSP
truck driven by defendant William Schoenberg. The NSP truck was
then rear-ende& by a police squad car,owned by the City of St. Paul
and driven by defendant Officer Francis Zaruba,which caused the NSP
truck to again strike plaintiff's vehicle. The witnesses testified
.
ADVANTAGESIFSiq�OYFA:ar force
11
Officer Zaruba testified that he was traveling behind the NSP
truck when he saw it begin to brake. Zaruba immediately applied
his brakes but was unable to stop before striking the NSP vehicle.
The forae of the collision was sufficient for the airbags to deploy
in Zaruba�s squad.
DISAWANTAGES IF'APPRO '
neck and shoulder pain. Durinq the next several months,
Mrs. McBeath's condition deteriorated and she began having loss of
sensation and strength in her right arm. These symptoms,affected
her ability to manipulate objects as well as affecting her
penmanship. She saw several neurologists who identified her
condition as related to the car accident. These neurologists
recommended a cervical laminectomy and fusion surgery be performed.
DISADVANTAGESIFNOTAP e en an s a an Independen Me ical Examina ion
performed on Mrs. McBeath by an orthopedic'surgeon. That doctor
concurred with Mrs. McBeath's treating physicians that her current
symptoms were related to the car accident.'The doctor also aqreed
that Mrs. McBeath was highly likely to require fusion surgery in
the future as a esu�t of he�r,,�njury. The cost of such a procedure
�„ f, r,-�� ��.-
'c���4:�� i.s��G��v �.aa�.F':�
����� i � ����
TOTALAMOUNTOFTRANSACTION $ �-7 SOO.00 COST/REVENUEBUDGETED(CIfiCLEONE) YES NO
FUNDINGSOURCE Tort L].a}.�111'ty � V �ACTIVITVNUMBER 090�0
FINqNCIAL INFORMATION: (EXPLAIN) �
�� ��
is approximately $35,000.00. To date, Mrs. McBeath has incurred
roughly $8,000.00 in medical bills. Mrs. McBeath's husband, Stuart
McBeath, brought his own claim for loss of consortium, alleginq
that her injuries had affected the quality of their marital
relationship:
On January 9, 1997, all parties met for court-ordered
mediation, during which the parties agreed to a proposed
settlement, subjeet to City Council approval, of all of the
McBeaths' claims, for a total payment of $55,000.00 with $17,500.00
to be paid by the City of St. Paul and $37,500.00 to be paid by
NSP. Given the liability issues and the extent of Mrs. McBeath's
injuries, this office recommends settlement of this matter in the
amount of $17,500.00.
�����E�;���
Presented By
Referred To
1
2
3
4
5
6
7
8
Council File � \� `�'�
Green Sheet # 3113�
RESOLVED, that upon execution and delivery of a release, in full, to the City of
St. Paul, the proper City officers are hereby authorized and directed to pay out of the
Tort Liability Fund, 0907-0511, to Patricia McBeath and Stuart McBeath and Sieben,
Polk, Laverdiere, Jones & Hawn, their attorneys, the sum of $17,500.00 in full settlement
of their claims for damages arising out of a motor vehicle accident with a city vehicle at
or near Leacington Avenue and University Avenue on July 21, 1994.
Requested by Department of:
City Attorne
By:
Approved by Mayor: Date
s /� (G ��rGL�
By: (l.;.r�--�— .!j . i--a-�--..
Form Approved by City Attorney
$ � � . ,--�......
Ar� oved by Mayor for Submission to
Council
By: ' " �- � C�'�^"'�J
RESOLUTION
CITY OF SAINT PAUL, MINNESOTA �
Adopted by Council: Date� ,��\qq�
Adoption Certified by Counc'1 Secretary
qZ bZ
DEPARTMENT/OFFICE/COUNCIL DATE INRIATED O
c�t Attorney Ol/14/97 GREEN SHEE N_ 31 138
CANTACTPERSONBPMONE ODEPqRTMENTDiRECfOR �CITYCOUNqL INITIAIJDATE
Theodore D. Leon, 266-8747 ���N �CITYATTORNEY �c
NUNBERFOR
MUSTBE ON CAUNCILAGENDA BV (DATE) ROUTING � BUIX'aET DIRECTOR � F
ORDEX � MqyOR (Ofl ASSIS O
TOTAL # OF SIGNATURE PAGES � (CLIP ALL LOCATIONS FOR SIGNATURE)
ACfIpN REQUESTED: �/ ��
1 f
Approval of resolution settling the claim against the City of
St. Paul by Patricia McBeath and Stuart McBeath for $17,500.00.
RECAMMENDATIONS: Mprove (A) ar Reject (R) PERSONAL SERVICE CONTRACTS MUST ANSWER TXE FOLLOWING �UESTIONS:
_ PLANNING CqMMISSiON . _ C4VIL SERVICE COMMISStON �� Has this person/firm e�er worketl under a contrac[ for this departmen[? �
_ q6 CoMMITfEE _ YES NO
_ STAFF 2: Has this person/firm ever been a city employee?
— YES NO
_ DIS7RIC7 COUR7 _ 3. Does this erson/Firm ossess a skill not normall
p p y possessed by any current ciry employee?
SUPPORTSWHICHCAUNqL�&IECTIVE? � YES NO
Explain all yes answers on separete sheet antl attach to green shcet
INITIATING PROBLEM. ISSUE, OPPORTUNITV (Who. Whet, When, Where. NTy):
On July 21, 1994, plaintiPf Patricia McBeath, a Yifty eight
year old woman, was stopped on southbound Lexington Avenue near
Aurora Avenue to make a U-Turn when she was rear-ended by an NSP
truck driven by defendant William Schoenberg. The NSP truck was
then rear-ende& by a police squad car,owned by the City of St. Paul
and driven by defendant Officer Francis Zaruba,which caused the NSP
truck to again strike plaintiff's vehicle. The witnesses testified
.
ADVANTAGESIFSiq�OYFA:ar force
11
Officer Zaruba testified that he was traveling behind the NSP
truck when he saw it begin to brake. Zaruba immediately applied
his brakes but was unable to stop before striking the NSP vehicle.
The forae of the collision was sufficient for the airbags to deploy
in Zaruba�s squad.
DISAWANTAGES IF'APPRO '
neck and shoulder pain. Durinq the next several months,
Mrs. McBeath's condition deteriorated and she began having loss of
sensation and strength in her right arm. These symptoms,affected
her ability to manipulate objects as well as affecting her
penmanship. She saw several neurologists who identified her
condition as related to the car accident. These neurologists
recommended a cervical laminectomy and fusion surgery be performed.
DISADVANTAGESIFNOTAP e en an s a an Independen Me ical Examina ion
performed on Mrs. McBeath by an orthopedic'surgeon. That doctor
concurred with Mrs. McBeath's treating physicians that her current
symptoms were related to the car accident.'The doctor also aqreed
that Mrs. McBeath was highly likely to require fusion surgery in
the future as a esu�t of he�r,,�njury. The cost of such a procedure
�„ f, r,-�� ��.-
'c���4:�� i.s��G��v �.aa�.F':�
����� i � ����
TOTALAMOUNTOFTRANSACTION $ �-7 SOO.00 COST/REVENUEBUDGETED(CIfiCLEONE) YES NO
FUNDINGSOURCE Tort L].a}.�111'ty � V �ACTIVITVNUMBER 090�0
FINqNCIAL INFORMATION: (EXPLAIN) �
�� ��
is approximately $35,000.00. To date, Mrs. McBeath has incurred
roughly $8,000.00 in medical bills. Mrs. McBeath's husband, Stuart
McBeath, brought his own claim for loss of consortium, alleginq
that her injuries had affected the quality of their marital
relationship:
On January 9, 1997, all parties met for court-ordered
mediation, during which the parties agreed to a proposed
settlement, subjeet to City Council approval, of all of the
McBeaths' claims, for a total payment of $55,000.00 with $17,500.00
to be paid by the City of St. Paul and $37,500.00 to be paid by
NSP. Given the liability issues and the extent of Mrs. McBeath's
injuries, this office recommends settlement of this matter in the
amount of $17,500.00.
�����E�;���
Presented By
Referred To
1
2
3
4
5
6
7
8
Council File � \� `�'�
Green Sheet # 3113�
RESOLVED, that upon execution and delivery of a release, in full, to the City of
St. Paul, the proper City officers are hereby authorized and directed to pay out of the
Tort Liability Fund, 0907-0511, to Patricia McBeath and Stuart McBeath and Sieben,
Polk, Laverdiere, Jones & Hawn, their attorneys, the sum of $17,500.00 in full settlement
of their claims for damages arising out of a motor vehicle accident with a city vehicle at
or near Leacington Avenue and University Avenue on July 21, 1994.
Requested by Department of:
City Attorne
By:
Approved by Mayor: Date
s /� (G ��rGL�
By: (l.;.r�--�— .!j . i--a-�--..
Form Approved by City Attorney
$ � � . ,--�......
Ar� oved by Mayor for Submission to
Council
By: ' " �- � C�'�^"'�J
RESOLUTION
CITY OF SAINT PAUL, MINNESOTA �
Adopted by Council: Date� ,��\qq�
Adoption Certified by Counc'1 Secretary
qZ bZ
DEPARTMENT/OFFICE/COUNCIL DATE INRIATED O
c�t Attorney Ol/14/97 GREEN SHEE N_ 31 138
CANTACTPERSONBPMONE ODEPqRTMENTDiRECfOR �CITYCOUNqL INITIAIJDATE
Theodore D. Leon, 266-8747 ���N �CITYATTORNEY �c
NUNBERFOR
MUSTBE ON CAUNCILAGENDA BV (DATE) ROUTING � BUIX'aET DIRECTOR � F
ORDEX � MqyOR (Ofl ASSIS O
TOTAL # OF SIGNATURE PAGES � (CLIP ALL LOCATIONS FOR SIGNATURE)
ACfIpN REQUESTED: �/ ��
1 f
Approval of resolution settling the claim against the City of
St. Paul by Patricia McBeath and Stuart McBeath for $17,500.00.
RECAMMENDATIONS: Mprove (A) ar Reject (R) PERSONAL SERVICE CONTRACTS MUST ANSWER TXE FOLLOWING �UESTIONS:
_ PLANNING CqMMISSiON . _ C4VIL SERVICE COMMISStON �� Has this person/firm e�er worketl under a contrac[ for this departmen[? �
_ q6 CoMMITfEE _ YES NO
_ STAFF 2: Has this person/firm ever been a city employee?
— YES NO
_ DIS7RIC7 COUR7 _ 3. Does this erson/Firm ossess a skill not normall
p p y possessed by any current ciry employee?
SUPPORTSWHICHCAUNqL�&IECTIVE? � YES NO
Explain all yes answers on separete sheet antl attach to green shcet
INITIATING PROBLEM. ISSUE, OPPORTUNITV (Who. Whet, When, Where. NTy):
On July 21, 1994, plaintiPf Patricia McBeath, a Yifty eight
year old woman, was stopped on southbound Lexington Avenue near
Aurora Avenue to make a U-Turn when she was rear-ended by an NSP
truck driven by defendant William Schoenberg. The NSP truck was
then rear-ende& by a police squad car,owned by the City of St. Paul
and driven by defendant Officer Francis Zaruba,which caused the NSP
truck to again strike plaintiff's vehicle. The witnesses testified
.
ADVANTAGESIFSiq�OYFA:ar force
11
Officer Zaruba testified that he was traveling behind the NSP
truck when he saw it begin to brake. Zaruba immediately applied
his brakes but was unable to stop before striking the NSP vehicle.
The forae of the collision was sufficient for the airbags to deploy
in Zaruba�s squad.
DISAWANTAGES IF'APPRO '
neck and shoulder pain. Durinq the next several months,
Mrs. McBeath's condition deteriorated and she began having loss of
sensation and strength in her right arm. These symptoms,affected
her ability to manipulate objects as well as affecting her
penmanship. She saw several neurologists who identified her
condition as related to the car accident. These neurologists
recommended a cervical laminectomy and fusion surgery be performed.
DISADVANTAGESIFNOTAP e en an s a an Independen Me ical Examina ion
performed on Mrs. McBeath by an orthopedic'surgeon. That doctor
concurred with Mrs. McBeath's treating physicians that her current
symptoms were related to the car accident.'The doctor also aqreed
that Mrs. McBeath was highly likely to require fusion surgery in
the future as a esu�t of he�r,,�njury. The cost of such a procedure
�„ f, r,-�� ��.-
'c���4:�� i.s��G��v �.aa�.F':�
����� i � ����
TOTALAMOUNTOFTRANSACTION $ �-7 SOO.00 COST/REVENUEBUDGETED(CIfiCLEONE) YES NO
FUNDINGSOURCE Tort L].a}.�111'ty � V �ACTIVITVNUMBER 090�0
FINqNCIAL INFORMATION: (EXPLAIN) �
�� ��
is approximately $35,000.00. To date, Mrs. McBeath has incurred
roughly $8,000.00 in medical bills. Mrs. McBeath's husband, Stuart
McBeath, brought his own claim for loss of consortium, alleginq
that her injuries had affected the quality of their marital
relationship:
On January 9, 1997, all parties met for court-ordered
mediation, during which the parties agreed to a proposed
settlement, subjeet to City Council approval, of all of the
McBeaths' claims, for a total payment of $55,000.00 with $17,500.00
to be paid by the City of St. Paul and $37,500.00 to be paid by
NSP. Given the liability issues and the extent of Mrs. McBeath's
injuries, this office recommends settlement of this matter in the
amount of $17,500.00.