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Bretz 7-12-23 rsps to claim JMW krl WALDECK & PATTERSON, P.A. 5000 WEST 95TH STREET, SUITE 350 PRAIRIE VILLAGE, KS 66207 Telephone: (913) 749-0300 Fax: (913) 749-0301 WEBSITE: http://www.waldeckpatterson.com PRAIRIE VILLAGE, KS • KANSAS CITY, MO July 12, 2023 Via email: matt@bretzinjurylaw.com Matthew L. Bretz Bretz Injury Law 3 Compound Drive PO Box 1782 Hutchinson, KS 67504-1782 Re: Cassandra Warner Date of Incident: 6/25/2021 NOTICE OF CLAIM RESPONSE Our File No. 1120.33190 Dear Mr. Bretz: We have been retained to represent the Salina Airport Authority (“SAA”) to respond to your Written Notice of Claim on behalf of Ms. Warner. We are specifically responding to your April 3, 2023 Written Notice of Claim sent to the Salina Airport Authority Board of Directors, and Clerk of the Salina Airport Authority Board of Directors. Based on our investigation, the SAA is not liable for your client’s fall. From your notice and our investigation, your client slipped and fell at the entry point of the open walkway leading from the airport ramp to the terminal building as she was deplaning Flight #5064 from Denver. Earlier that day the area experienced significant rain, that moisture was on the concrete ramp and the open walkway entrance where your Notice indicates the fall occurred. The condition was not affirmatively caused by any employee or person affiliated with the SAA. As a result, the SAA and its employees are not responsible for your client’s injuries. In addition, even if the municipality immunity for natural conditions under the Kansas Tort Claims act does not completely bar the claim, the conditions present were open and obvious with warnings placed in the walkway for arriving passengers, such as your client, regarding the alleged conditions. This denial is based on the information that was provided in your Written Notice of Claim. If you have any additional information you wish to be considered, please forward it to our attention. July 12, 2023 Page 2 On this basis, please consider this correspondence a denial of the claim against SAA presented in your April 3, 2023 12-105b notice. Very truly yours, WALDECK & PATTERSON, P.A. /s/ John M. Waldeck John M. Waldeck Direct Dial: 913-749-0310 johnw@waldeckpatterson.com JMW/krl