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RE 01-03-91.1 A RESOLUTION OF THE CITY OF COPPELL, TEXAS RESOLUTION NO.010391.1 A RESOLUTION OF THE CITY OF COPPELL, TEXAS, APPROVING A SETTLEMENT AGREEMENT CONCERNING AN ASSESSMENT LEVIED AGAINST HATTIE MAE LESLEY AND HER PROPERTY PURSUANT TO PAVING AND OTHER CONSTRUCTION ON BELT LINE ROAD AUTHORIZED BY RESOLUTION NO. 102886.1 AND ORDINANCE NO. 86-367; AUTHORIZING THE MAYOR TO EXECUTE SUCH AGREEMENT, AUTHORIZING THE MAYOR TO EXECUTE ANY INSTRUMENTS NECESSARY TO CARRY OUT THE TERMS AND INTENT OF THE AGREEMENT INCLUDING ANY INSTRUMENTS NECESSARY TO RELEASE AND CANCEL ANY LIEN IMPOSED AGAINST SAID PROPERTY AS A RESULT OF SAID ASSESSMENT AND RELEASE AND CANCEL THE CERTIFICATE OF ASSESSMENT; AND DECLARING AN EFFECTIVE DATE. WHEREAS, Coppell levied an assessment in the amount of $533,216.18 against Hattie Mae Lesley and her property (the "assessment") to cover a portion of the costs to be incurred for paving and other construction of Belt Line Road (N/S) adjacent to her property; and WHEREAS, said assessment was levied by City of Coppel! Resolution No. 102886.1 and Ordinance No. 86-367; and WHEREAS, the City of Coppell issued Certificate of Special Assessment Number 89-101 relating to the assessment against Hattie Mae Lesley and said property; and WHEREAS, Hattie Mae Lesley has contested the assessment, including within her contest, her contention that much of her property is her homestead and therefore exempt from the imposition of an assessment Hen, but has agreed to settle such assessment by paying the City of Coppell the sum of $225,000.00; and WHEREAS, the City of Coppell has agreed to accept such sum in settlement of said disputed assessment, lien, and certificate, and the parties' agreement to dismiss their claims in the law suit. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF COPPELL, TEXAS: SECTION 1. That the City Council of the City of Coppell, Texas, hereby approves the Settlement Agreement between the City of Coppell and Hattie Mae Lesley, a copy of which is attached hereto, and authorizes the Mayor to execute such agreement settling the disputed assessment, lien, and certificate levied against Hattie Mae Lesley and her property for the sum of $225,000.00. The Mayor is further authorized to execute any instruments necessary to carry out the terms and intent of the agreement including any instrument necessary to release and cancel any claim against Hattie Mae Lesley and any lien imposed against said property as a result of said assessment and cancel and release Certificate of Special Assessment No. 89-101. SECTION 2. That this resolution shall become effective immediately upon its adoption and passage. DULY ADOPTED AND PASSED by the City Council of the City of Coppell, Texas, on the 3rd day of January, 1991. THE CITY OF COPPELL, TEXAS MAYOR~/ ! ATTEST: CI~ ~CRETARY APPROVED AS TO FORM: CR~1-0103 CERTIFICATE OF AUTHENTICITY THE STATE OF TEXAS COUNTY OF DALLAS CITY OF COPPELL I, Dorothy Timmons, City Secretary of the City of Coppell, Texas, hereby certify that the above and foregoing is a full true and correct copy of the original resolution now in my lawful custody and possession, filed in the office of the City Secretary of the City of Coppell, Texas, on the ~ day of ,~_'.-~.. , 19 ~/ and as the same is recorded in my office in the Official Book ofc~Resolutions of the City of Coppell, Texas, as Resolution Number 010391.1 , duly a~dopted and passed by the City Council of the City of Coppell on the.~,e~ day of ~.~-- , 19~/ . I certify on this the /-/~'~ day of ~.~,.~-~ , 19~/ . Dorothy Timmon~ -J City Secretary(/ City of Coppell, Texas STATE OF TEXAS COUNTY OF DALLAS Before me, the undersigned authority, personally appeared Dorothy Timmons, known to me to be the City Secretary of the City of Coppell, Texas. I hereby certify that she is the official City Secretary of the City of Coppell, Texas, and her signature to the foregoing Certificate Of Authenticity is genuine. I certify on this the /~/~_ day of :/~//}~ , 19~/. .~,~s~.~. Notary Public, State of Texas Printed Name of Notary My Commission Expires ~..~/. /~/ _ k '-.' / ~.t,~.;.,";,.~ 7.; · ' FIGARI & DAVENPO. ATTORNEYS AND COUNSELORS 901 Main Street, LB 125 1 Dallas, Texas 75202 / writer'~ Direct Dial ~umber 214-939-2~ ~ (214) 939--2007 3anuarv 18, 1991 Mr. Lawrence W. Jackson Sallinger, Nichols, Jackson Kirk & Dillard 1800 Lincoln Plaza FILED FOR BEOOBD 500 North Akard Street Dallas, Texas 75201 JAN g 81991 Ms. Dorothy Timmons, City Secretary City Secretary City of Coppell - City Hall Dept. 255 Parkway Blvd. P. O. Box 478 Coppell, Texas 75019 Re: Cause No. 86-15013-B, Hattie Mae Lesley vs. The City of Coppell Dear Larry and Dorothy: Enclosed please find a file-stamped copy of the Agreed Motion to Dismiss and a copy of the Agreed Final Judgment of Dismissal that was entered by the Court on January 16, 1991. I believe the enclosed items are self-explanatory. It was a pleasure to represent the City in connection with this matter. Although the result was not as favorable as we had hoped for, I certainly consider the settlement to be a reasonable one. Of course, if you have any questions or comments regarding the foregoing, or require any further assistance in connection with this or any other matter, you should not hesitate to contact me. Sincerely, Don Colleluori DC/rs Enclosure cc: Mr. Frank Trando, w/enclosure NO. 86-15013-B HATTIE MAE LESLEY, IN THE Plaintiff, VS. DALLAS CO~TY~ CITY OF COPPELL, TEXAS, D~fendant. 44TH JUDICIAL DISTRICT AGREED MOTION TO DISMISS TO THE HONORABLE JUDGE OF SAID COURT: Come now Plaintiff Hattie Mae Lesley and Defendant the City of Coppell, Texas, and move the Court to enter an order of dismissal in this action, and in support thereof, would show the Court the following: I. Plaintiff and Defendant have compromised and settled all the claims and disputes between them that were the subject of this action. WHEREFORE, PREMISES CONSIDERED, Plaintiff and Defendant respectfully request that the Court enter a final judgment dismissing all of the claims and counterclaims asserted herein with prejudice, with costs taxed against the party incurring same. AGREED MOTION TO DISMISS - PAGE 1 Respectfully submitted, FIGARI & DAVENPORT ~rnest E. Figari, Jr. State Bar No. 06983000 Donald Colleluori State Bar No. 04581950 4800 NCNB Plaza 901 Main Street Dallas, Texas 75202 (214) 939-2000 (214) 939-2090 Telecopy No. ATTORNEYS FOR DEFENDANT CITY OF COPPELL, TEXAS JORDAN, DUNLAP & PRATHER Robert C. Prather State Bar No. 16235000 Jerry N. Jordan State Bar No. 11013000 8115 Preston Road, Suite 500 Dallas, Texas 75225 (214) 696-6060 (214) 696-6724 - Tetecopy No. ATTORNEYS FOR PLAINTIFF HATTIE MAE LESLEY AGREED MOTION TO DISMISS - PAGE 2 HATTIE MAE LESLEY, IN THE DISTRICT COURT OF Plaintiff, VS. DALLAS COUNTY, TEXAS CITY OF COPPELL, TEXAS, Defendant. 44TH JUDICIAL DISTRICT AGREED FINAL JUDGMENT OF DISMISSAL Came on to be considered the Agreed Motion to Dismiss, and the Court, having reviewed the Motion, and the other pleadings on file herein, and being otherwise fully advised, finds and~concludes that such Motion is well-taken and should be granted. It is, therefore, ORDERED, ADJUDGED, and DECREED that all of the claims asserted in the above-entitled and numbered action by Plaintiff Hattie Mae Lesley against Defendant The City of coppell, Texas be, and the same hereby are, dismissed with prejudice; and it is further ORDERED, ADJUDGED, and DECREED that all of the counterclaims asserted in the above-entitle~ and numbered action by Defendant The City of Coppell, Texas against Plaintiff Hattie Mae Lesley be, and the same hereby are, dismissed with prejudice; and it is further ORDERED, ADJUDGED, and DECREED that all costs of suit shall be taxed against the party incurring same. AGREED FINAL JUDGMENT OF DISMISSAL - PAGE i SIGNED this /~-~day of January, 1991. JUDGE PRESIDI~NG APPROVED AND AGREED TO AS TO FORM AND SUBSTANCE FIGARI & DAVENPORT Don Colleluori 4800 NCNB Plaza 901 Main Street Dallas, Texas 75202 (214) 939-2000 ATTORNEYS FOR PLAINTIFF JORDAN, DUNLAP & PRA~HER Robert C. Prather Jerry N. Jordan 8115 Preston Road, Suite 500 Dallas, Texas 75225 (214) 696-6060 , ATTORNEYS FOR PLAINTIFF HATTIE MAE LESLEY AGREED FINAL JUDGMENT OF DISMISSAL - PAGE