Fladwood (2) �� PritzkerOlsen attorneys
RECElVED
JUN 06 �Q�3
�une 4, 2o�s CITY CLERK
VIA CERTIFIED MAIL
City of St. Paul
ATTN: City Clerk's Office
City Hall
15 Kellogg Boulevard West
St. Paul, MN 55102
Re: Our Client: Delmer V. Fladwoed -
Date of Loss: 1/4/2013
Dear Sir/Madam:
This office represents Delmer V. Fladwood for injuries sustained in an incident on January 4,
2013. Mr. Fladwood was in proximity to a tree that was being cut down by employees of the
City of St. Paul. He was struck by a large limb of the tree that was projected toward him when
the trunk of the tree fell on the limb. Mr. Fladwood suffered severe injuries including two
fractured femurs, a fractured tibia, a fractured fibula, and an arterial injury.
Please turn this letter over to the City's liability insurance carrier so they may have an adjuster
contact me.
Please also refer to our Notice of Claim, which is attached.
Thank you.
Si ' y, i
��
Efliot L. Glsen
elliot(a�pritzkerlaw.com
ELO/sk ,
Enclosure
CC: Delmer Fladwood
Telephone 6iz.338.ozo� Plaza Seven Bldg.,Ste.z95o �� '❑�
Toll-Free i.888.377.8900 45 South Seventh Street �
Fax 6iz.338•oio4 Minneapolis,MN 554oz �
www.pritzkerlaw.com Justice for Injured People"
�� PritzkerOlsen attorneys
NOTICE OF CLAIM IN ACCORDANCE WITH
MINN. STAT. §466.05, SUBD. 1
TO: City of St. Paul
C/O City Clerk's Office
310 City Hall
15 West Kellogg Boulevard
Saint Paul, MN 55102
PLEASE TAKE NOTICE that Delmer Fladwood and Roxanne Fladwood of 625 Grand
Avenue, St. Paul, Minnesota 55103 hereby claim damages against the City of St. Paul in excess
of $50,000.00 by reason of personal injuries sustained by Delmer Fladwood on January 4, 2013
at approximately 1:45 p.m. At that time, Mr. Fladwood was in proximity to a tree that was being
cut down by employees of the City of St. Paul. Mr. Fladwood was not warned of any danger or
asked to move out of the area. He was then struck by a large limb of the tree that was projected
toward him when the trunk of the tree fell on the limb. Mr. Fladwood suffered severe injuries
including two fractured femurs, a fractured tibia, a fractured fibula, and an arterial injury.
Said injuries and damages occurred as a result of the negligence of the City of St. Paul
and its agents and employees in failing to properly secure the area and warn bystanders and in
the use of substandard tree removal techniques.
Dated: June 4, 2013 PritzkerOlsen, P.A.
�
By.
�
Ellio L. Olsen (#203750)
Attorneys for Claimants/Plaintiffs
Delmer Fladwood and Roxanne Fladwood
Suite 2950 P�aza V(i 8uii�ing
45 South 7th Street
Minne polis, MN 55402-1652
(612) �38-0202
Telephone 6iz.338.o2oz Plaza Seven Bldg.,Ste.z95o ❑� � '❑�
Toll-Free i.888.377.8900 45 South Seventh Street �—
Fax 6iz.338.oio4 Minneapolis,MN 554oz �
www.pritzkerlaw.com Justice for Injured People"