Alexander Ct-CS081015
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Ken Griffin - RE: Latest Interrogatories
Ken Griffin
From:
To:David T. Ritter
10/15/2008 4:34 PM
Date:
Subject:RE: Latest Interrogatories
David Dodd
CC:
Attachments:Alexander lawsuit.xls
David
I've attached my attempt at a response to request for information reviewed at the Council meeting. I'm
not sure if it means anything, but he is requesting information for the August 29, 2007 Council meeting
which was a Wednesday and there was no Council meeting. The response may be that no documents
exists for the 29th.
Anyway, let me know what I need to do from here.
Ken Griffin
>>> "David T. Ritter" <dritter@toase.com> 10/8/2008 11:57 AM >>>
Ken:
I'm reviewing the discovery set now. I am working on responses to some of it, but we'll need you to
answer Interrogatory No. 7. The answer to Interrogatory No. 8 will be largely identical, but may include
additional documents reviewed by the park staff and the tree retention staff who testified at the August
City Council meeting. The documents you've selected will be responsive to Request for Production
numbers 10 and 11, respectively. I'll work on answers to Interrogatory 4-6, but please don't hesitate to pull
any that you think are responsive as you perform your review; we can discuss when we meet.
Another development in the case is that Mira Mar has obtained new counsel. In my most recent
discussion, he seemed much more focused on the City Counsel meeting than Walt, and the discovery in
this set is geared towards exploring the City's rough proportionality analysis prior to the hearing and the
presentation at the hearing.
After we've had a chance to review the respective documents, I'd like to arrange a meeting to go over the
findings. Are you available on Monday or Tuesday of next week?
Thanks,
David
From: Ken Griffin [mailto:kgriffin@ci.coppell.tx.us]
Sent: Monday, October 06, 2008 10:40 AM
file://C:\Documents and Settings\radloo\Local Settings\Temp\XPgrpwise\48F61B85City_o...2/22/2010
Page 2 of 2
To: David T. Ritter
Cc: Clay Phillips; Robert Hager
Subject: Latest Interrogatories
David
I've had no contact on the latest request. Is the requested information something that you will be
providing based on the information previously provided by the city? Or, do I need to prepare answers
to the questions?
Thanks
Ken Griffin, P. E.
Director of Engineering & Public Works
972-304-3680
kgriffin@ci.coppell.tx.us
file://C:\Documents and Settings\radloo\Local Settings\Temp\XPgrpwise\48F61B85City_o...2/22/2010
Response to Plaintiff’s Second Set of Interrogatories in Cause No. 07-11511
Dated September 16, 2008
At the August 28, 2007 City Council meeting, I spoke for 25 minutes in response to a presentation by persons representing Mira Mar. During the 25 minutes, I
addressed 16 different topics. Of those 16 topics, I referenced material in 12 topics. The following represents the 16 topics and material referenced on 12 topics. I was
requested to “identify the documents relied upon”. The instructions define “identify” as “with respect to a document means the title, general description of topics covered,
date, preparer(s) and recipient(s).
General Description
Topic DiscussedTitleDatePreparer(s)Recipient(s)
of Topics Covered
n/a
1
Fill In Floodplain
Provides information City of Coppell /
Preliminary Digital
on property in the Texas State NFIP
Federal Emergency
Flood Insurance Rate floodplain and the Coordinator / North
Floodplains need Revision6/22/2007
2
Map and Flood associated 100 year Management AgencyCentral Texas Council
Insurance Studywater surface of Governments /
elevation.Carter & Burgess
Map prepared by
Floodplain elevations Map - 4/2007 &
Kimley-Horn. Color
Color Coded MapCity of Coppell
associated with Color Coding -
coding provided by
various flood studies.07/2007
Ken Griffin
Kimley- Horn Study
3
Flood Study for
1990 Kimley-Horn
rebuilding of the
10/31/1990Kimley- HornCity of Coppell
Flood StudyDenton Tap bridge
over Grapevine Creek
Dirt Work in Floodplainn/a
4
General Description
Topic DiscussedTitleDatePreparer(s)Recipient(s)
of Topics Covered
Floodplain Covers all aspects of
6/26/2001City of CoppellCity of Coppell
Management development in a
Ordinancefloodplain.
Provides fully
Elevating Building Pads
5
developed floodplain
City-Wide Stormwater Albert H. Halff
limits and elevations /
1/1/1991City of Coppell
Management StudyProvides solutions for Associates, Inc.
various drainage
problems around town.
Shows information on
Bethel Road
City of Coppell
how Bethel will be
Preliminary Plans
reconstructed
Impact Fee Capital Provides information
Full Credit for Dedication
Freese and Nichols,
Improvement Plan - on how to calculate an
6
of Right of way
8/1/2005City of Coppell
Water, Wastewater, impact fee and the fee Inc.
and Roadwayto be accessed
Provides accessed Dallas County
DCAD InformationOnline
valuation of propertyAppraisal District
Fee change to $2000 -
Shows fees to be
City of Coppell Fee
11/13/2001 & Fee
Pay for Flood StudyCity of Coppell
charged for various
7
Resolutionchange to $2500 -
services
5/22/2007
Covers development
Sidewalk to NowhereSubdivision Ordinance4/12/1994City of Coppell
8
of property
General Description
Topic DiscussedTitleDatePreparer(s)Recipient(s)
of Topics Covered
Covers development
Subdivision Ordinance4/12/1994City of Coppell
of property
Rolled Curb
9
Standard Construction Regulate Infrastructure 5/12/1992 & Revised
City of Coppell
DetailsConstruction5/10/2005
Covers development
Subdivision Ordinance4/12/1994City of Coppell
of property
Inlets
10
Drainage Design
Design of drainage5/1/1993City of Dallas
Manual
Slopesn/a
11
Screening Wall in
n/a
12
Easement
Letter of Map
5/23/2007 & Kimley- Horn and
Flood Study Review LettersReview of flood studyCity of Coppell
Revision (LOMR)
13
6/27/2007Associates, Inc.
Review
Construction Detail
Use of Rolled CurbsStreet construction5/10/2005City of Coppell
14
2035
Standard Construction Regulate Infrastructure 5/12/1992 & Revised
Street CapsCity of Coppell
15
DetailsConstruction5/10/2005
Analysis of street
Street Capacity AnalysisLetter8/3/2007Tim Bennett, P. E.City of Coppell
16
capacity