Alexander Ct-CS081214
(2/22/2010) Ken Griffin - Re: Mira Mar v. City of Coppell lawsuitPage 1
From:
Libby Ball
To:
Brad Reid,John Elias,dritter@toase.com
CC:
Clay Phillips,Ken Griffin,ddodd@njdhs.com,cadkins@toase.com,dferguson@to...
Date:
12/14/2008 1:00 PM
Subject:
Re: Mira Mar v. City of Coppell lawsuit
David - - -
I have researched documents in response to my portion of the Production of Documents.
The Rules and Procedures Ordinance which was in effect for the requested time can be found at:
http://weblink.ci.coppell.tx.us/weblink7/DocView.aspx?id=8370&dbid=0
The Home Rule Charter which was in effect until November 2006 can be found at:
http://weblink.ci.coppell.tx.us/weblink7/DocView.aspx?id=9457&dbid=0
In November 2006 we had an election to amend the Charter by adding Section 11.22, the canvass of
which can be found at:
http://weblink.ci.coppell.tx.us/weblink7/DocView.aspx?id=16445&dbid=0
The Home Rule Charter which has been in effect since the November 2006 election can be found at:
http://weblink.ci.coppell.tx.us/weblink7/DocView.aspx?id=20813&dbid=0
If you need hard copies of these documents from me or to have the documents certified and mailed to
you, please let me know and I will forward as soon as possible.
Libby Ball, City Secretary
City of Coppell
255 Parkway Blvd. - P. O. Box 9478
Coppell, Texas 75019
972/304-3670
972/304-3673 (fax)
lball@ci.coppell.tx.us
www.ci.coppell.tx.us
>>> "David T. Ritter" <dritter@toase.com> 12/10/08 4:49 PM >>>
ATTORNEY-CLIENT and ATTORNEY-WORK PRODUCT PRIVELEGED DOCUMENT
Mr. Reid, Mr. Elias, and Ms. Ball:
Per an earlier conversation with Clay Phillips, I am attaching a copy of
the Plaintiff' Third Request for Production of Documents that has
recently been served on the City in the Mira Mar v. City of Coppell
case. This request for documents has been sent by the Plaintiff's
lawyer seeking documents relevant to the August 2007 City Council
hearing of Mira Mar's appeal of the fees that the City charged. The
City will need to send documents responsive to these requests on
(2/22/2010) Ken Griffin - Re: Mira Mar v. City of Coppell lawsuitPage 2
December 24. In order to give us time to review the documents and make
any objections, we are requesting that any responsive documents be given
to us by December 17th.
We feel that many of these requests have already been responded to;
however, there are some new materials and supplementation that we will
need your help in answering. The particular questions that we need
information from you are:
Mr. Reid and Mr. Elias - RFP #2 and 3. The plaintiff wants the City to
identify any documents that you relied upon in calculating or justifying
the park and tree mitigation fees discussed at the August 28, 2007
Council Meeting. I have attached a spreadsheet that Ken did in response
to a similar RFP (#1). We'll also need copies of the documents, if they
haven't already been produced to the plaintiff. If any other staff
members besides you or Ken reviewed or relied upon documents or aided in
the fee determination for any of the contested fees, please also inquire
if they used any additional documents besides the ones you relied upon.
If it would be helpful to refresh your memory regarding your testimony
at the hearing, I have a transcript available that I can get to you.
Ms. Ball - RFP #5, 6, and 7. The plaintiff is inquiring about any City
Council ordinances, procedures or rules governing City or City Council
meetings and hearings that were effective from January 2006 to the
present, particularly those adopted pursuant to Section 3.12 of the City
Charter. Also, RFP # 14 & 15. The plaintiff is asking about any rules
regarding a deadline that the Council had to make a ruling after a
hearing. I anticipate that if the City has any such rules, they would
be covered in the responses to 5, 6, and 7, but just want to make sure
we check for anything deadline-specific.
As far as the other RFP's, I anticipate that we will make the following
responses and objections: RFP #! 1 - Ken has already given me the
attached spreadsheet, and we have previously produced these documents;
RFP 4 (City Charter) is available online; RFP 8-13, I am reviewing, as I
believe that we have likely produced at least a significant portion of
these earlier in the litigation.
Thanks for your help in this matter - please do not hesitate to contact
me if you have any questions.
(2/22/2010) Ken Griffin - Re: Mira Mar v. City of Coppell lawsuitPage 3
David T. Ritter
Attorney-at-Law
Taylor, Olson, Adkins, Sralla & Elam, L.L.P.
6000 Western Place, Suite 200
Fort Worth, Texas 76107-4654
Voice: 817.332.2580
Fax: 817.332.4740
dritter@toase.com <mailto:dritter@toase.com>
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