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Alexander Ct-CS081015 Page 1 of 2 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