NOTICE OF CLAIMRe: Joaquin G. Mesa-Vazquez
3540 South 22nd Street
Milwaukee, Wisconsin 53204
Date of Accident: July 24, 2023
Location: West Lapham Boulevard & South 10th Street Milwaukee, Wisconsin
THE STATE OF WISCONSIN, TO: Alan J. Sackmann
833 South 119th Street
West Allis, Wisconsin 53214YOU ARE HEREBY NOTIFIED that we represent the Claimant named above, who has filed a Notice of Claim against you.
YOU ARE HEREBY FURTHER NOTIFIED, pursuant to Wis. Stat. § 893.80, that on or about October 10, 2023, a Notice of Injury was filed on behalf of Joaquin G. Mesa- Vazquez for injuries he sustained while he was the operator of a motor vehicle traveling eastbound on West Lapham Boulevard, at or near the intersection with South 10th Street, in the City and County of Milwaukee, Wisconsin; that at the same time and place, Alan J. Sackmann was the operator of a county-owned vehicle, traveling southbound on South 10th Street, when he negligently operated the county-owned motor vehicle and created an unsafe condition, causing a collision with the motor vehicle operated by Joaquin G. Mesa-Vazquez, thereby causing his injuries and damages; and that at the time of the accident, upon information and belief, Alan J. Sackmann was operating the county-owned vehicle in the course and scope of his employment with Milwaukee County.
Liability for Joaquin G. Mesa-Vazquez's injuries and damages is attributed to Milwaukee County pursuant to the theory of vicarious liability, including the doctrine of Respondeat Superior, in that they are liable for the acts of their aforementioned employees, servants, agents, and/or volunteers acting within the course and scope of their duties, in this case, Alan J. Sackman, who operated the county-owned vehicle while in the course and scope of his employment, agency, and/or contract with Milwaukee County, resulting in Joaquin G. Mesa-Vazquez's injuries and damages.
PLEASE TAKE FURTHER NOTICE that as a proximate result of the negligence described in the Notice of Injury, Joaquin G. Mesa-Vazquez sustained injuries causing him to incur medical bills and expenses as follows:
(a) Aurora Healthcare $10,166.81 to date
(b) Sixteenth Street Community Health Center $ 525.00
(c) Personal Property Damages $ 11,635.00
Total to Date: $22,326.81
As a proximate result of the negligence described in the Notice of Injury, Joaquin G. Mesa-
Vazquez suffered conscious pain and suffering in addition to the special damages outlined above in an amount of $300,000.00.
WHEREFORE, Joaquin G. Mesa-Vazquez demands $250,000.00 from Milwaukee County.
DATED at Milwaukee, Wisconsin, this 15 day of April 2024.
HUPY AND ABRAHAM, S.C.
Attorneys for the Plaintiff,
By: Electronically signed by Todd R. Korb
Todd R. Korb
State Bar Number: 1026950Post Office Address
111 East Kilbourn Avenue
Suite 1100
Milwaukee, Wisconsin 53202
Phone Number: (414) 223-4800
Email: TKorb@hupy.com2604388/4-18-25/5-2