File Ref. #011
November 19,
ANGELO R. POD, P.A.
+rTORNEY AT LAW
R E eEl V E:U22 S,W, 67th Avenue
91 NOV 2lt PH si1ri, Florida 33155
CITY CLERK'S OFFICE
1997
OJ! -POll ~/97
J4A-lJA- SANl1f jA.~il>&fvi
FAX: (305) 262-1740
PHONE: (305) 262-3520
CERTIFIED MAIL #: Z 198 056 013
RETURN RECEIPT REQUESTED
City of Miami Beach
1700 Convention Center Drive
Miami Beach, FL 33139
Attn.: Hon. Mayor, Neisen Kasdin.
Re: My Client
D/A
Location of Accident
MARIA SANTA
May 13, 1997
Normandy Dr. at or near
Rue Versailles, Miami Beach, FL.
Hon. Mayor:
My client, MARIA SANTA, of 6930 Rue Versailles, Apt. # 31, Miami
Beach, Florida 33141, sustained serious personal injuries
resulting from the above captioned accident. The accident
happened when Mrs. Santa tripped and fell at the above location
which was littered with debris from the construction that was
taking place on the street, curbs and sidewalks in the area.
This accident is the responsibility of one or more of the
following entities:
The City of Miami Beach,
The Florida Dept. of Transportation,
Metropolitan Dade County, and/or
Church and Tower Co.
All and/or anyone of the above four mentioned entities/companies
are responsible for the serious injuries sustained by my client.
It is quite clear that the dangerous and hazardous condition was
negligently created by the responsible parties when they left the
area around the construction site full of construction debris
causing my client to tripp and fall. I am sending you this
notice, pursuant to any and all applicable codes and statutes.
My client, MARIA SANTA, was born in San Vicente, Colombia, and
her date of birth is February 20, 1920. Her Social Security
number is 158-46-6567. As required by Statute, at this time,
there is no case style or tribunal, and there are no adjudicated
penalties, fines, fees, victim restitution funds or judgments in
excess of $ 200.00 owed by the claimant to the State, its
agencies, offices or sub-divisions.
Con It. . .
w
City of Miami Beach
Attn.: Hon. Mayor Neisen Kasdin
November 19, 1997
Page 2
Certified Mail # Z 198 056 013
Ret. Rec. Requested
Kindly acknowledge this letter and advise me of the name of the
person who will be handling this claim.
Very truly yours,
ANGELO R. POU, P.A.
Ange~ II. ~
ARP/ns
cc:file
cc: Risk Management Dept.
Florida Dept. of Insurance
150 Larson Building
Tallahassee, FL 32304
Sent via Certified Mail
Return Receipt Number:
Z 186 690 402
cc:
Clerk, Dade County Commission
Metro-Dade Center
111 N.W. 1st. Street
Suite 210
Miami, FL 33128-1983
Mr. Richard Brown ~
Clerk, City of Miami Beach
1700 Convention Center Dr. - Sent via regular mail
Miami Beach, FL 33139
Sent via Certified Mail
Return Receipt Number:
Z 186 690 404
cc:
cc: Mr. Ben Watts
Secretary of Transportation
State of Florida - Sent via regular mail
The Haydon Burns Building
Tallahassee, FL 32301
cc: Mr. Ted Baldasarre
Director, Risk Management Dept.
City of Miami Beach Sent via regular mail
1700 Convention Center Drive
Miami Beach, FL 33139