File Ref. #089 ~[EI~IBER OF FLORIDA BAR,
FEDERAL BAR ASSOCIATION,
DISTRICT OF COLUMBIA BAR
August 25, 1998
DENNIS G. KING, P.A.
ATTORNEY AND COUNSELLOR AT
MIAMI, FLORIDA
(3o5)
RECEIVED
98 15,1JG 2 8 11:18
CiTY CLER ,'S To:
POST OFFICE BOX 330735
COCONUT GROVE STATION
MIAMI, FLORIDA 33233-0735
City Clerk, or Duly Authorized Officer
City of Miami Beach
1700 Convention Center Drive
Miami Beach, FL 33139
Re: Phillips v. City of Miami Beach doa 3/15/98
TO WHOM IT MAY CONCERN:
This letter will serve as Notice of the claim of Ricky E. Phillips
pursuant to Fla. Stat. 786.28. Failure to respond within six (6)
months shall be deemed a denial of this claim subjecting the City
to suit therefor.
On or about 10:30 A.M., Sunday, March 15, 1998, Ricky Phillips was
riding his bicycle on Collins Avenue when a City of Miami Beach
police vehicle driven by Officer Andrew J. Kuncas was so negligently
driven so as to collide with the claimant at the intersection of
13th St. causing him to be thrown to the payment and suffer serious
injury. Claimant sustained three fractures of the leg and ankle,
and suffered permanent injury, scarring, property damage to the
bicycle, and has been damaged incurring medical expenses, and loss
of income due to inability to work. We hereby demand $100,000 in
settlement of this claim.
Ricky E. Phillips was born October 31, 1959 in Washington County,
Virginia, City of Bristol. His Social Security # is 227-02-5897.
He owes no money to any state, agency, officer or subdivision.
Please provide pursuant to Fabre v. Martin, 623 So.2d 1182(1993)
~_~,~
~ names of any and all witnesses, and the names of any persons or
entities who you contend are responsible for claimant's injuries.
Failure to do so will constitute an admissie '? such ;~t.
We await your response.
e
Certified P 062 451 510 V r~g_~
cc D . YKIYN~ ~ A.
Fla. Dept of Insurance
Certifed P 062 ~51 537 '- _
Ricky Phillips
Zeller & Keihner, L.L.P.