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XVII. <br />That the negligent and improper acts of the County, as described above, were a <br />direct and proximate cause of the wrongful death of Kristin Lorenz, and in addition have <br />caused Plaintiff to incur expenses for the last treatment and funeral expenses of the <br />decedent and to sustain pecuniary loss within the meaning of Minn. Stat. § 573.02. The <br />total damage sustained by Plaintiff as a direct and proximate result of the negligent and <br />improper acts of the County is in excess of Fifty-Thousand Dollars ($50,000.00). <br />SECOND CAUSE OF ACTION <br />XVIII. <br />For his second cause of action, Plaintiff realleges and incorporates herein the <br />allegations set forth in Paragraphs I. through XVII. <br />XIX. <br />That the Defendants, and each of them, were required to safely and properly <br />place the utility pole in relation to the roadway, and to ensure the safe and proper <br />condition, construction, inspection, replacement, restoration, repair and maintenance of <br />the subject pole and surrounding area. <br />XX. <br />That the Defendants were negligent and failed to exercise due care, which <br />negligence introduced or permitted the continued existence of dangerous and <br />unreasonably hazardous conditions, and which negligence included, without limitation, <br />the unsafe and improper placement of the utility pole so that it was too close to the <br />roadway; the failure to properly inspect, replace, restore, repair and maintain the pole <br />6 <br />