ST8402-CS 900322 (2)~OPPET.~. POBLI~ NOI~S
~ch 22,
TO:
FROM:
RE:
1990
Wayne Ginn, City C.onsulting Engineer
Wayne, I received the above referenced claim from our Personnel
Department and I am submitting a copy to your office in order that
you can forward it to the contractor.
Should you have any questions regarding this matter, please contact
me or if I'm not available speak with the Administrative Secretary
Sheri Moino.
SGG/sm
cc~ Vivyon V. Bowman, Assistant City Manager/Personnel Director
MEMORANDUM
TO:
FROM:
~eve Goram, Director of Public Works
~ v on V. Bowman, Assistant city Manager/
~Y Personnel Director
DATE:
March 15, 1990
SUBJECT: claim
Please find attached a claim submitted by Mr. Tony Gregory and also
correspondence from his attorney regarding this claim.
in the contractor has agreed under
Based upon my understand. ~, .... ~-~ ~ 1 claims submitted
contract to indemnify the Cl~y o~ coppe~ ~ ..... 1
during construction of this project.
Please contact or have the appropriate representative contact the
contractor on this claim to resolve this matter.
Please contact me with any questions and/or need for further
information.
WB/dj
xo:
Alan D. Ratliff, city Manager
Larry Jackson, city Attorney
Dorothy Timmons, City Secretary
City Secretary
City of Coppell
P.O. Box 478
GINSBERG, BRUSILOW AND WALK~3~
TELECOPIER (214) 702-0662
March 14, 1990
Coppell, Texas 75019
Re: Claim of Tony Gregory for damages
Dear City Secretary:
Our firm represents Mr. Tony Gregory in connection with the
damages Mr. Gregory suffered by reason of the City of Coppell's
failure to have a barricade in front of a section of road in
Coppell which was under construction. This has been verified by
witnesses as well as the police report which was made at the time.
Mr. Gregory's car was seriously'damaged when the car he was
driving plunged into a hole in the street because no barricade was
in place. The accident occurred on. December 10, 1989, and he
submitted his written report to you on or about December 12, 1989.
Mr. Gregory obtained an estimate of the cost to repair, a copy of
which is enclosed. The estimated cost to repair was $2,195.62.
Mr. Gregory was initially advised· by the City of Coppell to
contact the insurance company of the construction company that was
doing the work for the city. This was done and the insurance
company is unwilling to be responsible. Therefore, unless my
client receives a check for certified funds in the amount of
$2,195.62 payable to Tony Gregory within 7 days from the date of
this letter, we will have no choice.but to proceed with all legal
remedies available.
Your prompt attention to this matter is appreciated.
Ver~y truly yours,
David Brus ilow
DB/kc
Enclosure
cc: Mr. Tony Gregory
deb/c/c
CLAIM NOTICE (FOR OFFICE USE)
CLA'[M NO.
· I.~ OFF~~ '~ '~ ~ ....
claim against the City of Cop~ll.~e
~is is my notice of
circ~stances giving rise to this claim are as foll~s:
1. The injury or damage occurred on the '~ day of /~d6'f,n~,
19~Q at approximately ~ o'clock p~ · at the s~cific
location of ~0,~ ~m~ ~.~-~ ~'~ ~'~f> in Cop~ll, Te~s-
2. The d~age or injury occurred in the following manner:
~/~,v~l~.-j ~,~A ~.~ 0~+.,~ ~.p_~ i~ C/F~,,~
3. ~e full extent of my d~ages and/or injuries are as
follows (~ s~cific; attach estimates, bills, etc., if available): ~d~l/ ~f~,~,~ ~;~J~ e3~3 1~,4~,~ ~oi,' Z3"L2 '~') ,~' -~ IO-f3'~.
4. The amount of damages claimed is $
(please print)
ADDRESS,2~O S. pgoc0cH,,,~ ~/~ CITY/STATE
I DO SWEAR THE ABOVE IS TRUE AND CORRECT
NOTE: ARTICLE II, Section 11.09 of the Home Rule Charter -
Damage Suits.
The notification shall be filed within forty-five (45) days of
the date of injury or damage or, in the case of death, within
forty-five (45) days of the date of death. The failure to so
notify the city within the time and manner specified shall
exonerate, excuse and exempt the city from any liability
whatsoever. No action at law shall be brought against the city
until at least sixty (60) days have elapsed following the date
of notification.
~14/242.1089
214/242-1295
L~on's Collision Center
1325 Whitlock Ln.//201
Carrollton, Texas 75006
All Work Guaranteed
ESTIMATE OF REPAIRS
PARTS' J$
NET & SUBLET