Coppell Cross 1P-CS 990924MEMORANDUM
Date:
To:
From:
Subject:
September 24, 1999
Ken Griffin, City Engineer
Gary Sieb, Planning D~or
Jim Witt, City ~
Mavex Coppell Crossfng v. City of Coppell
Attached is a letter from Plaintiffs attorneys forwarded by Darrell Noga. Our meeting
concerning this matter is scheduled for Tuesday, September 28 at 2 p.m. with City Attorney Bob
Hager.
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Enclosure
09.'2%
Tt{£' l(:'l'i7 FAX 214 712 9540
COOPER & SC['LLY,P.C.
002
COOPER & SCULLY
September 23, 1999
Direct Line:
(2la) 712-9505
Jim Wits, City Manager
C;iW of Coppeli
255 Parkway Blvd.
P O. Box 478
Coppell, Texas 75019
Via Fax. 972/304-7063
Re;
Mavex Coppell Crossing v. City of Coppell, Texas
U.S. District Court, Northern District of Texas, Dallas Division
Civil Action No. 3-99CV0125-P
Our File No. 257/6558
Dear Jim'
Per our recent discussions, please review the attached letter I recently received from
PlaintifFs attorneys relative to the above, which provides you with some details as to the
d,,:w:lopment issues involved. As I noted, Plaintiff's attorneys advise they are quite flexible
in negc, tiatmg the dollar amom~t of the credits they seek, and they appear willing to exchange
~he curt'cut dismissal order for one dismissing th/s case with prejudice if we can resolve what
appear to be these fmrly minor matters.
I've also copied Bob Hager on this letter and ask you both to please feel free to call me
xv~th any questions or cormnents, or to advise if I eau be of further assistance. Please also keep
me advised of' developments on your end. As always, I look forward to hearing from you.
DGN/c~
2521~.6
truly yours,
Darrell G-M Noggin//
Robert E. Hager (w/enclo. via fax 214/965-0010)
4:lorneys -.4 Profvaaic, na/ Corporat,on
Founders Squ~¢ 900 Jttck~on Street, Suite 100 Dallas. Texas 75202
le lephone ~ 14 '712-9500 Fax 214.712'9540
Sheman Office 903-813'3900
FAX 21..1 712 9540 COOPER
Da~ell G-M Noga~ Esq.
COO?ER &
900 ]'ackmn S~..
Suite 100
Dallas, Iexas 75202
September 21, 1999
RE:
3~qve.,~ L:5ot~e ll CrossirLz LOts 4_and ~5
_~2805.186,4~
Our Kef: '~ '
Dear Darrell:
Thank you for the oppommity ~o meet with you on September 10, 1999 to discus~ tke
developm~m! in Coppell by my c!ient, M~v~x Coppel[ Crossing. Pursuem to your request for
clarifica~on a~-, ~o my cliem's specific request, plv~se be advised of the follo,~4.ng.
With respect to Lot 4, request i.s made (i) to relem ti~e City of Coppe[l requirement for a
t0 £oot lm~dsc~I>e p~me~er ~o~d ~e ~ of Lot 4 ~d to ~stead allow landscaping ~o~d
the perimeter of Lot 4 as sho~ on ~e drawings ~endered to you d~g o~ meeting on
$eptemb~ :0, 1999 ~d (fi) to ~low c~it on impact fee~ cb~ged for ~e developmem of Lot 4
~n ,m mno~t w~ich, when add~ to ~e ~c~t request fo~ Lot 5, is ~ to ~e ~o~t spent by
Mavex to move ~he box cuiven on Lot 5 (tvtfl cost of approximately
With respect :o Lot 5, req~aes~ i~ made (i) to relax the City of Coppell requLremenl for a
10 foot landscape perimeter around the emirerv of Lot 5 and to ~st~ad allow landscaping around
th.,:: perimeter of Lot 5 as Shown on the drawLngs tend~exl to you dur/r~ o'0$ meeting on
September ID, ~999, (ii) to allow Ma~,ex m move ae box culvert on the hearth-west portion of
Lot 5 from its em:em location to the loeafio~ ~hovm on the drawings :ender~ to you during our
a~ezhr~g on September 10, 1999, and (iii) to allow credit on impact fees eh~g~cl for the
devetopment of Lot 5 in an v, motmt which, when ~lded m the credit request for Lot 4, is equal to
the muotmt spent by b~,'ex to move the box culvert on Lot 5 (total cost of apptoximately
$85,0O0)
Please contact me if :Sarflxe: ¢l~ificat[on is requested. Thaxflc you for your mssistanee in
mat~er.
214 712 9540
COOPER & SCULLY,P.C.
004
cc: ?,{ax, ex Coppelt Crossing