ST9302-CL010320 AGAINST THE CITY TRANSMITTAL FORM
DISTRIBUTION LIST: j
Jim Witt, City Manager
Bob Hager, City Attorney
Viwon BossTnan, Director of HR
Texas Municipal League
Lawsuit File (original/copy)
"'\TV~lCTR'.USERS'. KwdkersX, Cl~ Forms ~Suit Transmittal Form doc
Revised 8; 19
STq3o2.
LAWSUIT/CLAIMS AGAINST THE CITY TRANSMITTAL FORM
DISTRIBUTION LIST: //
Jim Witt, Ci~' Manager
Bob Hager, Ci~' Attorney
Viwon Boxwnan, Director of HR
Texas Municipal League
Lawsuit File (original/copy)
COlVlMENTS:
'. ',TIa,.~_CTR',USERS',Kwilkers\CIaah Forms' Suit Transmittal Form.doc
Revised 8; 19.94
Sen; By: Law Offzce; 2148C02884; Mar-2O.3~ 11:40AM; Page
THE LAW OF'F~C£S OF
Rastegar & Associates
Attorneys & Counselors at
6060 N. CENTRAL ExP'~l'.. SU,TE #560
DALLAS, TE~ 75~06
TEL H~rO: {97~)5~9- 1009 F~: (2 I 4)800-2884
SHAY EASTEGAR JOHN H. EEAD
NAZEH ABUSAAD OF COUNSEL
Ci~' of Copp¢]l
P.0. ~o~ 478
Coppell. Texas 75019 VIA CERTIFIED ~t4IL NO. 7000-0520-0018-6554-0135
Re: Notice of pe~onal inju~- and damage claim of Amir Jahani and Mondonna Kodvand
De~ Sir/Made:
Pursuit to Section 101.101 of the Texas Civil Practices & Remedies Code, you are given notice of
the ton claim of Amir Jahani and Mondonna Kodvand, claimants.
On or about J~u~' 13, 2001 at 7:30 or 8:00 p.m., the above-stated claimers fell into a deep cavil'
while &lying om of the alley at 101 Heather Glen in Coppell, Texas. Tbs deep hole wm made by
the Cib' ~Wor its employees/agents for ~e p~ose of some reconst~ction of the streets ~at is
happe~ng in the ~ea. The claimers automobile fell into this invisible ditch o~y because the
had f~led to place ~y w~ings at ~at place as stated by the police at the scene. The clhm~ts
i~ies ~d d~ages ~e a direct ~d proximate result of the negligent conduct of the Ci~' of Coppell
~d:or employees/agents.
As a result of the occ~ence. Amir Jahani and Mondonna Kodvand have suffered physical
injuries compensable by law. The cl~m~ts ~e cu~ently ~der medicfl c~e of the doctors ~d ~e
extent and the pe~anency of their inj~es ~e not cle~ at ~is time.
Ifa claim fo~ is required for ~ese ~e of claims please fo~'~d s~e to us.
We would, of co,se, prefer to scale this maner without litigation. But if we have not received
acceptable senlement from you within a reasonable time. Amir Jahani and Mondonna Kodvand
will file suit ~d p~sue all remedies provided by law.
Ve~, t~lv yours.
g~
T H E C I T Y O F
COPP-EE£
July 18, 2001
Mondonna Kodvand
5612 Bedford Lane
The Colony, TX 75050
Dear Mr./Ms. Kodvand:
This letter is to notify you that your claim against the City has been forwarded to the
insurance company of the contractor working on road construction in the area at the time
of your accident. Therefore, the contractor is responsible for the claim.
The name of the insurance company is: Ed Bell Construction
P.O. Box 540787
Dallas, TX 75354-0787
The name of the contact person is: Nancy Johnson
Her telephone number is: 214-358-6581
Please contact Nancy with any comments/concerns regarding your claim.
Since/rely,
Vivyoff V. Bowman //--'~
/
Director of Administration/HR
cc: Nancy Johnson
Ken Griffin, City Engineer
Jim Witt, City Manager
Clay Phillips, Deputy City Manager
255 PARKWAY :~ P O BOX 478 1IrCOPPELL TX 75019 ~ TEL 972/462 0022 ~lrFAX 972/304 3673