ST9401-CL000630HERMES SARGENT BATES
A LIMITED LIABILITY PARTNERSHIP
ATTORNEYS AND COUNSELORS
JENNIFER L. NOLTE
214.658.6511
jennifer.nolte @hsblaw.com
June 30, 2000
City of Coppell
Engineering Department
Mr. Garreth Campbell
P. O. Box 478
Coppell, Texas 75019
Re: Cause No. DV -98 -02486
Paragon Communications v. East Texas Construction, Inc., et al.
Our File No. 0239100002
Dear Mr. Campbell:
This law firm represents S.J. Louis Construction, a party included in the above
reference case. S. J. Louis was hired by the City of Lewisville to perform road
construction along Denton Tap Road in Lewisville, Texas. This lawsuit revolves around
a fiber optic cable, which was cut during the course of ongoing construction regarding an
area called the Denton Tap Road Project. Subdivisions to the east and west of Denton
Tap Road were under construction. There was also construction for the 121 Bypass
underway not far from the Denton Tap Project.
Around the time that the Denton Tap Project was underway, there were several
other construction projects in progress in the same area. It is our understanding that the
City of Coppell was also involved some construction during the time periods of April 1,
1997 through July 31, 1997 in the vicinity of Denton Tap Road and Highland Road.
As per your request, the purpose of this correspondence is to request you to
discuss with us and/or provide documents regarding any construction projects the City of
Coppell was involved in during this time period involving the subject area. Also, if you
were monitoring the progress of the work being performed on the Denton Tap Road
Project, we would like to request a copy of your daily log or notes regarding this project
site for the time period in question. It is also our understanding that the west side of
1717 MAIN STREET SUITE 3200 DALLAS, TEXAS 75201
TEL. 214.658.6500 FAx 214.658.6300
Mr. Garreth Campbell
June 30, 2000
Pg. 2
Denton Tap Road is actually the City of Coppell, but we would ask that you provide any
information you have regarding this project.
Please give me a call to discuss this matter or if you are agreeable, a time at which
we might meet to discuss and/or review documents regarding this matter.
If you should need any further information, please do not hesitate to contact me.
Very truly yours;
ennife . Nolte
JLN/brs