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HomeMy WebLinkAboutDossTO: 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