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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 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 3 of 3