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NOTICE OF CLAIM
PURSUANT TO INDIANA CODE 34-13-3-8
THOMAS R. GALLIGAN, MAYOR
CITY OF JEFFERSONVILLE
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
ANNE MARIE GALLIGAN
ATTORNEY FOR THE CITY OF JEFFERSONVILLE
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
RICHARD R. ELIJOTT
DIRECTOR OF CITY PARKS
1406 FREDERICK AVENUE
JEFFERSONVILLE, 1N 47130
PEGGY WILDER
CLERK TREASURER, CITY OF JEFFERSONVILLE
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
ROB WAIZ
JEFFERSONVILLE CITY COUNCIL PERSON
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
LESLIE MERKLEY
JEFFERSONVILLE CITY COUNCIL PERSON
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
VICKI CONLIN
JEFFERSONVILLE CITY COUNCIL PERSON
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
RON GROOMS
JEFFERSONVILLE CITY COUNCIL PERSON
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
NOTICE OF CLAIM
PURSUANT TO INDIANA CODE 34-13-3-8
(Continued)
BARBARA WILSON
JEFFERSONVILLE CITY COUNCIL PERSON
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
DENNY FRANTZ
JEFFERSONVILLE CITY COUNCIL PERSON
501 EAST COURT AVENUE
JEFFERSONVILLE, IN 47130
PLEASE TAKE NOTICE that Rodney A. Doss does hereby file his Notice of
Tort Claim, by and through his attorney, as follows, to wit:
1. That on or about the 7th day of July, 2002, at approximately 2:20 p. m., Rodney
Doss was an invitee of and was on the premises of the Jeffersonville Aquatic Center
located at 2107 Middle Road, Jeffersonville, Indiana.
2. That while on said premises as an invitee, Mr. Doss was using the equipment
of the Jeffersonville Aquatic Center, specifically, a water slide. As Mr. Doss was
traveling down the slide, he noticed that a young girl was in fi'ont of him who also
traveling down the slide, but at a more reduced rate. In order to avoid colliding with the
minor child and potentially injuring her, Mr. Doss attempted to slow himself by grabbing
at the side of the slide. When Mr. Doss made this attempt, the fiberglass, having just
been cut, lacerated his finger to the bone.
3. Mr. Doss sought treatment at the Aquatic Center but felt that the persons
rendering such treatment were too young and not appropriately equipped or trained to
handle his dilemma. Given this, Mr. Doss exited the Aquatic Center on his own power
and was transported, by his wife, to the Clark County Hospital.
4. Mr. Doss' finger required surgery to repair the significant laceration on his
finger, missed time from work, was limited to one handed activities during rehabilitation,
and has discovered that he has some level of permanent impairment to his finger. Mr.
Doss' occupation is one which requires precision dexterity inasmuch as he is required to
assemble computer boards with precision circuitry.
5. Mr, Doss' claim is continuing and is believed, at this time, to be worth One
Hundred Thousand Dollars and No Cents ($100,000.00).
6. The attorney for Rodney Doss is Paul M. Blanton of Blanton Law Office, LLC
located at 530 East Court Avenue, Jeffersonville, Indiana 47130.
Dated this the l ~day of December~
e~kl~lrL~ll~ LA/?_TOS,?_22701-10
BIlan'~Law Office, LLC
530 E{st Court Avenue
Jeffersonville, 1N 47130
PREPARED BY:
PAUL M. BLANTON, #22701-10
Blanton Law Office, LLC
530 East Court Avenue
Jeffersonville, 1N 47130
Telephone: (812) 282-1132
Facsimile: (812) 282-3188