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RECEIVED FEB 2 1 198~
ROBERT B. HARRIS, P.C.
POST OFFICE BOX 4383
ATTORNEY AND COUNSELOR AT LAW
120 N. WASHINGTON BRYAN, TEXAS 77801
TELEPHONE (713) 779-9646
February 18, 1983
~1s. Diane Jones
City Secretary
P.O. Box 9960
College Station, Texas 77840
RE: WOODSON LUMBER COMPANY OF CPJ.1ERON VS THE CITY OF
COLLEGE STATION, TEXAS and LYN~~ NE~1EC, LARRY RINGER,
BOB RUNNELS and ALVIN PRAUSE, INDIVIDUALLY.
Pre1imaryP1at on 6.25 acres, Crawford, Burnett
League, Woodson Village, 5th installment, Section 5,
College Station, Texas.
Dear ~.1s. Jones,
In accordance with Section 136 of the Charter for the
CityofColl'ege Station, Texas, June, 1980, this letter
shall serve as timely notice of "\tJoo:ds'on Lumber Company of
Cameron's intent to file suit for a vJrit of }1andamus, for
a "damage claim, and/or damage to property" caused by the
City of College Station, Texas, and Lynn Nemec, Larry Ringer,
Bob P..unne1s, and Alvin Prause, individually. The specific
areas of information requested inS~ctionl36 of the afore-
mentioned charter is provided as follows:
\rJHE~l :
Thedawages commenced upon the date which the
applicant filed the preliminary pI.at for approval
back on July 14, 1977, again on November 6, 1980,
and again on January 20, 1983' (the exact dates
being, privy to the City of College Station, Texas),
damages were realized at the City Council meetings
for the City of College Station held on 9/21/77,
12/10/81 and more recently on 1/27/83, and such
damages continue to accrue.
vJHERE :
At the College Station lv1unicipalBuilding, 2611
Texas Avenue, College Station, Texas, and at the
separate property described above. '
Page two
~<1s. Diane Jones
HOW: By the City Council's failure to approve
preliminary and final plats on the aforementioned
6.25 acres and by the above-named individuals
voting in a willful, malicious and illegal
manner to deny said plats. .
DAl-1AGES: a) reduced value: $275,000.00
b) lost profits : $3l9,200.00; engineering costs-
$6,356.25;excalated costs of putting in streets
water lin~s and sewer lines - $32,000.00; attorney
fees- $3,000. 00, plus accruedinter,est
c) exemplary damages: $720,000.00
d) costs of Court
NAMES OF \vITNESSES:
David Price
Don Garrett
The Council members
Planning and Zoning Commissioners
City Staff
City Officers for the City of College Station, Texas
Consulting Engineers, College Station, Texas
(all of such information being privy to the City
of College Station, Texas)
, ,Variousotller witnesses, expert and non-expert
to be pr,operly named and disclosed in accordance
with the Texas Rules of Civil Procedure
This information is provided to properly place the City
of College Station, Texas on notice that a legal action is
contemplated and intended by Woodson Lumber Company of Cameron
foravJrit of Mandamus and to recover damages suffered due
to failure of the Council of the City of College Station to
approve a preliminary plat on the aforementioned property.
The Right to amend and supplement the information herein pro-
vided is reserved and will be exercised in the proper legal
form pursu.anttothe Texas Rules of Civil Procedure.
Sincerely,
.
RobertB. Harris, p.e.
Attorney at Law'
./
RBH/agb
page three
}is. Diane Jones
I do hereby certify that this notice letter, prepared
pursuant to Section 136 of the ~harter for the City of College
Stat,ion, Texas, Jtlne, 1980, is being person-ally delivered
to the office~the City Secretary for College Station,
Texas this ~/~-" day of February, 1983.
~~<
ROBERT B.HARRIS, P.G.
Attorney for WOODSON LUMBER OF CAMERON
THE STATE OF TEXAS
COUNTY OF BRAZOS -
BEFORE :ME, the undersigned authority, on this day
personally appeare,d ,Robert B. Harris, known tome to be
the person whose name is subscribed to the foregoing
instrument and acknowledged' to me that he executed the
same for the purposes and consideration therein expressed.
GIVEN UNDER MY HAND AND SEAL OF OFFICE this the
:< 0 rfl..:-day of February, 1983.
Ch~ MF
Notary Pubic ~n and for
The State of Texas !
My commission expires: :2-1 ;1.. [r
HIJ OJ( ~ /J-- G - 84v-