ST8505-CS 881107The City With A Beautiful Fut
November 7, 1988
Mr, Kevin Peiffer, P.E.
Ginn Inc.
17103 Preston Road
Suite 100, LBll8
Dallas, Texas 75248
P,O. Box 478
Coppell, Texas 75019
214-462-0022
Dear Mr. Peiffer:
Please find attached a letter received November 2, 1988,
regarding notices of injury and claim for damages filed
by Donald C. McLeaish, Attorney on behalf of Marcario
Zuniga, et.al. Please process this claim with the appro-
priate contractor in connection with the Beltline Road-
North/South Improvement project.
If you have any questions and/or comments, please contact
Russell Doyle, City Engineer.
Sincerely,
Vivy~n V. Bowman,
Assistant City Manager
cc:
Alan D. Ratliff, City Manager
Dorothy Timmons, City Secretary
Russell Doyle, City Engineer
Neal Ulrich, Adjuster, AIC.
GAB Business Services, Inc.
1202 Richardson Drive, Suite 109
P.O. Box 130
Richardson, Texas 75086
November 1, 1988
ATTORNEY AND COUNSELOR AT LAW
P.O. BOX
210 SOUTH MAIN STREET
DUNCANVILLE. DALLAS COUNTY. TEXAS 7513~
TELEPHONE (214)
1-800-541-4641
CITY MANAGER
TO:
Mr. Alan D. Ratliff, City Mgr.
City of Coppell
P.O. Box 478
Coppell, Texas 75019
Honorable Lee Jackson,
County Judge, Dallas County
411 Elm - 2nd Floor
Dallas, Texas 75202
Texas Highway Department
7901 N. Interregional Hwy.
Austin, Texas 78761-5426
CERTIFIED MAIL #P 944862774
RETURN RECEIPT REQUESTED
CERTIFIED MAIL #P 944862775
RETURN RECEIPT REQUESTED
CERTIFIED MAIL #P 944862776
RETURN RECEIPT REQUESTED
FROM:
Marcario zuniga, Husband of Josephine Zuniga
Rosie G. Cuba, Ricardo Daniel Calvillo Nunez
Julie Dyvette Calvillo Nunez, Claudia Dee Brown,
and Mrs. Vela
The undersigned presents this notice of injury and claim for
damages under the Texas Tort Claims Act or The Charter of the
City of Coppell. The undersigned represents the above named
children and husband of Josephine Zuniga who was killed in an
accident on May 10, 1988, at 1200 South Beltline Road in the
City of Coppell, Texas where construction was taking place.
The accident occurred at 6:35 a.m. The police report shows
that Thelma Edith Fuentes drove her vehicle northbound at that
location and for unknown reasons drove to the right side of the
roadway jumping the curb and then overcorrected to return to
the roadway and crossed into the southbound lane colliding head
on with another car. "Due to the road construction the driver
of the other car had no room for evasive action." The death of
Josephine Zuniga was a failing to properly warn the public that
the road was in a dangerous condition, provide adequate
city of Coppell
Dallas County Judge
Texas Highway Dept
November 1, 1988
Page Two (2)
warning, and do all the things necessary to properly warn the
driver. As a direct and approximate result of the death of
Josephine Zuniga her husband has lost the benefit of her
services, companionship, and support. Her children are
Rosie G. Cuba age 25, Ricardo Daniel Calvillo Nunez age
15, Julie Dyvette Calvillo Nunez age 8, Claudia Dee Brown
age 20, and Mrs. Vela age 36. Her children have lost the
same and have incurred funeral expenses in excess of
$6000.00. Investigation is ongoing and further information
will be provided.
Respectively submitted,
...-'" .. /~- --~ _~:
/ ~ ~ .~ ./~,. .
~,,-/ ,~'~ ,.'
DONALD C. MCLEAISH
Attorney at Law
P.O. Box 380517
Duncanville, Dallas County, Texas 75138
VERIFICATION
STATE OF TEXAS
COUNTY OF DALLAS (
BEFORE ME, the undersigned authority, on this day per-
sonally appeared DONALD C. MCLEAISH, Attorney for Marcario
Zuniga, Rosie G. Cuba, Ricardo Daniel Calvillo Nunez, Julie
Dyvette Calvillo, Claudia Dee Brown, and Mrs. Vela, who being
by me duly sworn on their oath deposed and said that he has
read the above and foregoing notice and that every statement
contained therein is within their personal knowledge and true
and correct.
'~ONA~D C.
Attorney at Law
SUBSCRIBED AND SWORN TO BEFORE ME on the / -- day of
~%2~-~-: ., 1988, to certify which witness my hand and
official seal.
SUZAN'~E JOHNSON ~
Notary Public in and for Dallas
County, Texas