Professional Documents
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City of Amarillo Petition
City of Amarillo Petition
BW Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
106315-D-CV Potter County, Texas
By ________ Deputy
CAUSE NO. _ _ _ _ __
Plaintiff City of Amarillo files this Original Petition against Defendants Brandt
Engineers Group, Ltd. ("Brandt"), L.A. Fuller & Sons Construction, Ltd. ("Fuller"), and
intended to be conducted in the above-styled and numbered cause under Level3, as defined
3. Venue is proper in Potter County, Texas pursuant to Texas Civil Practice and
Remedies Code 15.002 in that Potter County is the county ofDefendant Fuller's principal
office in this state and because all or a substantial part of the facts giving rise to this action
4. This Court has jurisdiction because the amount in controversy is within the
IV. PARTIES
partnership doing business in the State of Texas. Defendant may be served with process
by serving its registered agent, Mary E. Brandt, 4537 Canyon Drive, Amarillo, Texas
79110.
limited partnership doing business in the State of Texas. Defendant may be served with
process by serving its registered agent, Mike Fuller, 9401 Amarillo Boulevard East,
company organized and existing under the laws of California, whose principal place of
business is located at 708 South Temescal, Suite 101, Corona, California 92879. The Texas
Secretary of State is the proper agent for service on Mission Clay Products, LLC because
MCP engages in business in Texas but has not designated or maintained a resident agent
for service of process in Texas. Thus, service of process must be obtained through service
on the Texas Secretary of State pursuant to the "long-arm" statute. Tex. Civ. Prac. & Rem.
office at P.O. Box 1839, Corona, California 92879 (mailing address) or 708 South
sewer collection system extension through various portions of the City of Amarillo ("the
Project"). Brandt specified and Fuller installed a gravity-fed, vitrified-clay pipe that was
manufactured by MCP.
10. Construction on the Project began in 2006 and continued through 2007.
Since that time, the vitrified-clay pipe itself has experienced deterioration, delamination,
quality, and sufficiency of the pipe and its installation, including, without limitation,
improperly located support bedding around the pipe and improper sloping of the pipe. The
defective nature of the pipe itself, its as-specified installation, and its actually installed
locations, resulting in sewer collapses, blockages, leaks, and injury to other property.
Fuller had an obligation to disclose to the City of Amarillo defects observed in the vitrified-
clay pipe and to correct same, but it failed to do so. The premature deterioration of the
vitrified-clay pipe has resulted in the failure of the sewer system itself along with separate
property damage to the City of Amarillo. In order to maintain the sewer system in
operation, the City was forced to install temporary bypasses around areas that had
forced to remove and replace the vitrified-clay pipe, its supporting bedding, and remediate
areas around the pipes. The failure of the pipe has also resulted in subsidence of City
streets and property above the pipe, as well as damage to City of Amarillo property,
11. The premature failure and deterioration of the pipe, as well as the resulting
property damage, have occurred at various locations at the Project. On information and
belief these failures have occurred continuously since the sewer system was placed in use.
12. The City incorporates paragraphs 1-11 as if fully set forth here.
13. The City of Amarillo entered into a valid written contract with Brandt to
perform the engineering design and construction administration of the Project. The City
performed its obligations under the contract by paying Brandt for the services Brandt
agreed to provide. Brandt failed to fulfill its contractual obligation in several ways,
pipe in the design as an approved option for the sewage system, in providing inadequate
specifications, and in failing to discover or notify the City of and otherwise protect the City
from defects and deficiencies in the pipe's installation at the Project. Such action and
inaction by Brandt constitutes breach( es) of contract, and violates the standard of care set
forth in the contract requiring Brandt to perform its services to the degree of skill and
these and other provisions in its contract. Brandt's failure to comply constituted a material
breach of its agreement, which breach has caused damages that the City of Amarillo
suffered, and continues to suffer. The City of Amarillo seeks direct and consequential
14. In accordance with 150.002 of the Texas Civil Practice and Remedies
Code, the City attaches the Certificate of Merit of Lori Cox as Exhibit 1, setting forth the
factual basis for the City's claims against Brandt. Exhibit 1 is incorporated by reference
Brandt - Negligence
15. The City incorporates paragraphs 1-14 as if fully set forth here.
16. Brandt owed the City of Amarillo a duty to design, prepare adequate
specifications, and to coordinate all design and construction efforts, and observe the
construction of the Project in a manner consistent with the standard of care for engineers
on similar projects. Brandt breached the duty by failing to perform its services on the
Project in a manner consistent with the applicable standard of care. Brandt's negligent acts
17. In accordance with 150.002 of the Texas Civil Practice and Remedies
Code, the City attaches the Certificate ofMerit of Lori Cox as Exhibit 1, setting forth the
factual basis for the City's claims against Brandt. Exhibit 1 is incorporated by reference
18. The City incorporates paragraphs 1-17 as if fully set forth here.
19. Brandt made false representations to the City of Amarillo regarding the
sufficiency of the design, drawings, and specifications produced by Brandt for the Project.
Brandt did not exercise reasonable care or competence with regard to communicating the
information in said design, drawings, and specifications. The City of Amarillo justifiably
relied upon Brandt's representations for the construction of the Project. Brandt's negligent
20. In accordance with 150.002 of the Texas Civil Practice and Remedies
Code, the City attaches the Certificate of Merit of Lori Cox as Exhibit 1, setting forth the
factual basis for the City's claims against Brandt. Exhibit 1 is incorporated by reference
21. The City incorporates paragraphs 1-20 as if fully set forth here.
22. The City of Amarillo entered into a valid written contract with Fuller to
construct the Project. The City perfonned its obligations under the contract by paying
Fuller for the services Fuller agreed to provide. Fuller breached the contract in several
ways, including, without limitation, by failing to install the vitrified-clay pipe sewage
system in accordance with the plans and specifications. Among other failures, Fuller failed
to meet specified elevation criteria and failed to properly install the support bedding around
the pipe.
comply constituted a material breach of its agreement, which breach has caused damages
that the City of Amarillo suffered, and continues to suffer. The City of Amarillo seeks
24. The City incorporates paragraphs 1-23 as if fully set forth here.
first class finish, good appearance, and satisfactory operation. Fuller also impliedly
warranted to perform its work in a good and workmanlike manner. Fuller breached these
warranties by failing to construct the Project in accordance with express and implied
warranties in the contract documents, the contractual standard of care, or the standard of
care applicable to a builder working on similar projects. These breaches were the
proximate or producing causes of damages, including property damages that the City of
Amarillo suffered and continues to suffer. The City of Amarillo seeks direct and
Fuller - Negligence
26. The City incorporates paragraphs 1-25 as if fully set forth here.
27. Fuller owed the City of Amarillo a duty to construct and supervise
construction of the Project in a manner consistent with the standard of care for builders or
contractors on similar projects. Fuller breached this duty by failing to construct the Project
in a manner consistent with the applicable standard of care, including, without limitation,
Fuller's failure to build per the Project's plans and specifications. Fuller's acts and
28. The City incorporates paragraphs 1-27 as if fully set forth here.
29. MCP is strictly liable for the manufacture, sufficiency, and provision of the
vitrified-clay pipe for the Project. The vitrified-clay pipe was defective and unreasonably
dangerous, resulting in the structural failure of the Project and causing damage to the City
contamination of adjacent soils, and street and surrounding property damage caused by
subsidence of soils surrounding the Project. MCP breached its duties by supplying
defectively manufactured vitrified-clay pipe and additionally in the marketing, sale, and
supply of the vitrified-clay pipe by failing to provide adequate instructions and/or warnings
the Texas Business and Commerce Code by manufacturing and providing defective
vitrified-clay pipe to the Project, which caused damages to the City of Amarillo including,
but not limited to, the costs associated with removal of the vitrified-clay pipe, installation
pipe's failure.
provided to the Project, resulting in the structural failure of the Project and causing damage
surrounding the Project. MCP's negligence has caused the City of Amarillo damages
including, but not limited to, costs associated with removal of the vitrified-clay pipe,
damaged by the pipe's failure. The City of Amarillo seeks direct and consequential
32. The acts and/or omissions ofMCP set forth in paragraphs 28-31 above were
the producing and proximate causes of Plaintiffs injuries and damages as herein set forth.
33. All of the conditions precedent to the filing of this suit under the contract(s)
or any applicable law and to Defendants' liability to the City of Amarillo for the claims
34. The City of Amarillo seeks damages for the repair and replacement of the
property damage from the defective work on the Project, direct and consequential
contractual damages, and all other special damages to which it may be entitled. Damages
sought are within the jurisdictional limits of the Court. Those damages exceed $1,000,000,
and the City of Amarillo seeks monetary relief over $1,000,000. Tex. R. Civ. Proc. 47.
35. Pursuant to Chapter 38 of the Texas Civil Practice and Remedies Code, the
City of Amarillo is entitled to recover, in addition to the amount of damages sued for, its
reasonable and necessary attorneys' fees incurred in the prosecution of this action at trial
36. Pursuant to Rule 216 of the Texas Rules of Civil Procedure, the City of
Amarillo hereby demands trial by jury on all contested issues of material fact.
37. Pursuant to Rule 194 of the Texas Rules of Civil Procedure, the City of
Amarillo requests that Defendants disclose the information or material described in Rule
XI. PRAYER
WHEREFORE, Plaintiff requests that Defendants be cited to appear and answer and
3. Plaintiff recovers its attorneys' fees and costs of suit through trial and any
Respectfully submitted,
-and-
By:
Martin W. Dies
State Bar No. 05853800
mwdies@dieshile.com
-and-
BEFORE ME, the undersigned authority, on this day personally appeared Lori
Cox. After being duly sworn, she stated that she has read this affidavit, has personal
knowledge of the factual statements contained herein, and that such factual statements are
I. "My name is Lori Cox and I am over eighteen years of age and have never
been convicted of a felony and am fully capable of making this Affidavit in all respects. I
am personally familiar with and have knowledge of the facts contained herein and they
since 2010, and am actively engaged in the practice of engineering in Texas. My Texas
in the practice of civil and structural engineering, including in the areas of forensic
I also have specific experience in the design and investigation of piping systems.
3. "I have reviewed the following documents and materials in preparing this
affidavit:
EXHIBIT
Engineers Group, Ltd. ("Brandt Engineers") for the Sanitary Sewer Main
Brandt;
ASTM C12-07; ASTM C301-04; ASTM C700-05; The 2003 and 2005
Replacement by CH2M;
used atop the pipes, observation of the pipe in situ and the bedding
during the excavation of the backfill and delamination of the interior of the
pipe; inspection of the pipe that had been removed and replaced and the
Engineers Group, Ltd. and the City of Amarillo based on my review of that agreement.
Through that agreement, Brandt Engineers was hired by the City of Amarillo to perform
preliminary design, final design, bid phase, construction phase, and closeout phase
services associated with the Project. The Consulting Services Agreement states that
Brandt Engineers would perform its services with the degree of skill and diligence
at the time and location that its services were performed. Brandt also agreed to make
reasonable efforts to guard the City against defects and deficiencies and to re-perform
Brandt with Brandt Engineers sealed the Project' s construction drawings and
confirmed that Mr. Brandt is a registered engineer in Texas (Professional Reg. No.
knowledge of the acceptable standards for the practice of engineering in the state of
Texas, including the standards applicable to the engineering tasks that Brandt Engineers
and Dwight L. Brandt performed or agreed to perform for the City of Amarillo. I am
Brandt, which included sanitary sewage collection system design, and administration and
Services Agreement and related Project documents, Brandt Engineers and Dwight L.
Brandt were required to provide design and construction observation services for the City
of Amarillo. Such services are defined as the "practice of engineering" by the Texas
the Project' s site, and interviews with City of Amarillo personnel, Ron Reed and other
Rimkus employees, the Project' s sanitary sewer piping system has failed and continues to
engineering practice that Brandt Engineers and Dwight L. Brandt negligently breached
the duty of reasonable care for engineers imposed by the Consulting Services Agreement
testing was performed. Sanitary sewers are well known for their highly
pipe was consistent with the effects of hydrogen sulfide gas on the pipe.
Hydrogen sulfide gas is naturally created within the sanitary sewer systems
The depth of the sanitary sewer system also made repairs to the system
problematic, at best. Pipe bursting is not ideal due to the size of the pipe,
depth of the pipe, and the limited length obtainable for each run. Sanitary
sewer lines of this size and depth should be carefully designed to ensure
there is no premature failure of the piping system. This was not done.
While VCP has been used for over 100 years, modem piping systems are
Premature VCP failures also occur due to improper installation of the pipe.
This is a known hazard with VCP and it intensifies as the pipe size
increases due to the difficulty in handling the pipe. This should have been
taken into account in the design process to eliminate potential failure areas.
pipe to ensure pipe integrity. Without proper pipe bedding, the weight of
the soils atop the pipe are not properly distributed around the pipe. This
causes unnecessary and excessive loading on the pipe itself. This loading
is absorbed by the hoop strength of the pipe. This is the strength within the
pipe to maintain a circular dimension to the pipe. Once the hoop strength
of the pipe is exceeded, the pipe deforms, cracks and breaks causing sags
installation to ensure the bedding material properly supports that pipe and
prone to premature failure. A review of the plans and specifications for the
installation of the VCP showed that the pipe bedding and backfill were not
properly specified for the soils in the area of the project. The soils for a
majority of the area were classified as a Pullman Clay Loam, which were
moisture to the soils supporting the bedding exacerbated the movement and
3. Inspection of the VCP in situ revealed the bedding materials used during
installation did not comply with the detail drawings provided in the plans.
The detail for VCP embedment required no less than 12 inches of class II
uncovered a majority of the area had no class II backfill atop the pipe. The
trench appeared to have been backfilled primarily atop the pipe with native
services would be aware of the critical nature of the pipe bedding and
backfill for VCP, the given depth of application and the soils in the area,
and would have ensured that the bedding and backfill complied with the
overburden/backfill loading was directly atop the VCP and not properly
the Project and creating the necessary construction documents, including drawings and
specifications, to convey the design's intent. Dwight L. Brandt sealed the plans and
specification for the project. By sealing the plans and specifications for the project,
Dwight L. Brandt and Brandt Engineers agreed to and represented that they took
professional responsibility for their engineering work, including the sufficiency of the
design. Based on my findings above, it is my opinion that plans and specifications did
not meet the professional standard of care for engineering in the State of Texas. The City
of Amarillo had the right to rely on the design and construction documents prepared by
Brandt Engineers and Dwight L. Brandt. The errors and omissions by Brandt Engineers
and Dwight L. Brandt listed above were a contributing cause to the failure of the
to comply with the applicable Certificate of Merit statutes, if any. I reserve my right to
My Commission Expires:
MALIA L. STORRER
Marion County
My Commission Expires
January 24, 2024
District Manager
In charge of business operations and personnel for the Indianapolis district office. Performs
investigations for insurance companies, law firms, and property owners involving construction
defects, roadway design and construction, maintenance of traffic plans, standard of care,
structural failure analysis, and damage from hurricanes, tornados, earthquakes,
ice/wind/snow, fires, explosions, blasting, construction vibrations, and differential foundation
movement. Evaluates water transmission lines, sanitary sewer collection systems and
elevated water storage tanks for proper construction and causation of structural failure.
Performs trip/fall and slip/fall investigations and verifies code compliance of facilities with
respect to premises liability. Proficient with Brungraber Mark I and the evaluation of bathtubs
for slip resistance. Proficient with the English XL variable incident tribometer and the
evaluation of slip resistance of walking surfaces. Evaluation of ladders and public walkways
and stairs for slip/fall and trip/fall incidents. Evaluation of floor mats and other
design/maintenance conditions at walkways and doors. Familiar with historic structures and
hospitality industry. Proficient with design and construction practices with regard to parking
lots, highways and structural sites. Develops cost estimates and designs repair protocol for
structural and highway projects.. Performs training of staff to ensure thoroughness of
inspections and technical review of reports. Conducts continuing education classes for
industry colleagues on timely engineering topics.
Performed hundreds of investigations for insurance companies, law firms, and property
owners involving construction defects, roadway design and construction, maintenance of
traffic plans, standard of care, structural failure analysis, and damage from hurricanes,
tornados, earthquakes, ice/wind/snow, fires, explosions, blasting, construction vibrations, and
differential foundation movement, performed slip/fall and trip/fall investigations and verified
code compliance of facilities. Opened West Region offices and managed operations of the
West and Southeast Regions, including the sinkhole group. Project experience includes:
Page 2
LORI L. COX, P.E.
Performed investigations for insurance companies, law firms, and property owners involving
construction defects, structural failure analysis, and damage from hurricanes, tornados,
earthquakes, ice/wind/snow, fires, explosions, blasting, construction vibrations, and
differential foundation movement. Opened Lexington Regional offices and managed
operations of the Lexington Office. Project experience includes:
Project Engineer
Performed hundreds of investigations for insurance companies, law firms, and property
owners involving construction defects, structural failure analysis, and damage from
hurricanes, tornados, earthquakes, ice/wind/snow, fires, explosions, blasting, construction
vibrations, and differential foundation movement. Performed trip/fall and slip/fall
Page 3
LORI L. COX, P.E.
investigations and verified code compliance of facilities with respect to premises liability.
Project experience includes:
Project Manager
Performed structural engineering functions on several large projects. Managed staff in private
sector design. Designed highways and infrastructure for several industrial parks, Kentucky
Transportation Cabinet, municipalites, subdivisions and retail developments. Designed site,
including parking for strip malls, banks, apartment complexes and for additions to the
Commonwealth of Kentucky Capitol Building Executive Office Building expansion. Project
experience includes:
Four Star Industrial Park (Dixon, KY). Designed infrastructure including water,
sewer, roadways, site grading and one million gallon elevated water supply storage
tank for 1250 acre industrial park.
Page 4
LORI L. COX, P.E.
Staff Engineer
Designed water distribution and sanitary sewer collection systems for rural areas of
Kentucky. Wrote development plans and performed economic analysis for grant applications
for rural areas to fund water and sewer systems.
Staff Engineer
Assisted in the design of several projects, including slope stability repair for a failed roadway,
design of airport access roads, pavement design for taxi way and runway for general aviation
airports, design of T-hangars for general aviation airports. Reviewed development plans for
general aviation airports to ensure FAA part 77 compliance.
Staff Engineer
Assisted in the design of several projects and developed written specifications for hot-in-
place asphalt recycling, SUPERPave and specialty asphalt mixes. Conducted asphalt
extractions, sampling and testing for specification conformance. Worked in Planning and
Design Divisions to determine route location and design conformance to FHWA and KyTC
standards. Designed various roadways throughout the state and evaluated the rural road
system and signage.
Page 5
LORI L. COX, P.E.
Assisted in the design of various highway projects and development of specifications for
highway work. Worked in the offices of Planning, Drainage, Specifications, Construction,
Design and Materials concerning the design and construction of roadway projects within the
Commonwealth of Kentucky.
Worked in the tort liability section of the Transportation Research Center regarding roadway
condition and assessments of tort claims filed against the Kentucky Transportation Cabinet.
Thinking Beyond the Pavement (KY Transportation Research Center, 8 hours) 2001
The Engineers Road to the Courthouse (1-2 hrs: 2011; Presented at National
Worley Conference in Memphis, TN and RJMW Conference in Charlotte, NC)
Moisture Damage and Repair of Wood Floors (1-2 hrs: 2011; Presented at National
RJMW Conference in Charlotte, NC and Northern California Claims Conference in
Sacramento, CA)
EIFS- Moisture Infiltration (2 hours: 2011 Worley Conference in Memphis, TN)
Hail Damage Assessments to Residential Roofs (4 hours, 2009, 2010)
Structural Damage from Seismic Events (4 hrs, 2008, 2009)
Construction Claims and Disputes (1 hr, 2012 presented at the Defense Trial
Counsel of Indiana)
Drainage and Moisture Intrusion (2 hr, 2012 presented at the Mutual Insurance
Companies Assoc. of Indiana (MICAI))
Diagnosing Earthquake Damage (4 hr, 2014)
Moisture Intrusion (1 hr, 2015 presented at Optimal Claims)
Commercial Roofing (1 hr, 2015 presented at Optimal Claims)
Diagnosing Earthquake Damage (4 hr, 2015, presented at the Worley National
Conference, Louisville, Kentucky)
Low Slope Commercial Roofs (3 hr, 2017, presented at the Worley National
Conference, Louisville, Kentucky)
Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
By ________ Deputy
Page 6
BW
STYLED City of Amarillo, Texas vs. Brandt Engineers Group, Ltd. et al.
(e.g., John Smith v. All American Insurance Co; In re Mary Ann Jones; In the Matter of the Estate of George Jackson)
A civil case information sheet must be completed and submitted when an original petition or application is filed to initiate a new civil, family law, probate, or mental
health case or when a post-judgment petition for modification or motion for enforcement is filed in a family law case. The information should be the best available at
the time of filing.
Address: Telephone:
Additional Parties in Child Support Case:
100 Congress Ave., Ste. 700 (512) 708-1250
Defendant( s)/Respondent(s): Custodial Parent:
City/State/Zip: Fax:
Brandt Engineers Group, Ltd.
(512) 708-0519 Non-Custodial Parent:
L.A. Fuller & Sons Construction,
State Bar No:
Mission Clay Products, LLC Presumed Father:
.- .'-- ---
,.,In'ur" orDama
Debt/Contract 0Assault/Battery
0Consumer/DTPA !EIConstruction
0Debt/Contract 0Defamation
0Fraud/Misrepresentation Malpractice
OOther Debt/Contract: 0Accounting
OLe gal
Foreclosure 0Medical
0Home Equity-Expedited OOther Professional
OOther Foreclosure Liability:
0Franchise Related to Criminal
0Insurance 0Motor Vehicle Accident Matters
0Landlord/Tenant 0Premises 0Expunction 0Enforce Foreign 0Adoption/Adoption with
0Non-Competition Product Liability 0Judgment Nisi Judgment Termination
0Partnership 0Asbestos/Silica ONon-Disclosure 0Habeas Corpus 0Child Protection
OOther Contract: OOther Product Liability 0Seizure/Forfeiture 0Name Change 0Child Support
List Product: OWrit of Habeas Corpus- 0Protective Order 0Custody or Visitation
Pre-indictment 0Removal of Disabilities 0Gestational Parenting
OOther Injury or Damage: OOther: _ _ _ _ __ of Minority 0Grandparent Access
OOther: 0Parentage/Paternity
0Termination of Parental
Other Civil Rights
OOther Parent-Child:
0Discrimination 0Administrative Appeal 0Lawyer Discipline
0Retaliation 0Antitrust/Unfair 0Perpetuate Testimony
0Termination Competition Osecurities/Stock
0Workers' Compensation 0Code Violations 0Tortious Interference
OOther Employment: 0Foreign Judgment OOther: _ _ _ _ __
Olntellectual Property
ViaE-filing 106315-D-CV
Caroline Woodburn
District Clerk
Potter County, Texas
P.O. Box 9570
Amarillo, Texas 79105-9570
Re: Request for Issuance: City ofAmarillo, Texas vs. Brandt Engineers
Group, Ltd., et al.
Enclosed please find three Request for Issuance forms for the above-referenced
matter. Note that one of the forms includes special instructions for information necessary
for long-arm service. Please prepare the citations for the parties listed on the forms and
email them to me at ame@aaplaw.com so that they may be served by private process.
Please also include Lucy Morton (lkm@aaplaw.com) on the email.
AME/lkm
Encl.
Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
By ________ Deputy
BW
TYPE OF SERVICE:
0 POTTER COUNTY SHERIFF *SERVICE FEE AND COPY FEE REQUIRED*
0 CIVIL PROCESS SERVER-AUTHORIZED PERSON TO PICK-UP:------------------
0 POSTING *SERVICE FEE AND COPY FEE REQUIRED*
0 PUBLICATION *SERVICE FEE REQUIRED*
0 CERTIFIED MAIL *SERVICE FEE AND COPY FEE REQUIRED*
0 TO BE MAILED TO PARTY REQUESTING SERVICE *SELF ADDRESSED STAMPED ENVELOPE AND/OR POSTAGE
FEE REQUIRED*
D!] TO BE EMAILED TO PARTY REQUESTING SERVICES-MUST INCLUDE EMAIL ADDRESS
TITLE OF DOCUMENT: Plo.j()tiff 's Or~icA) Pe:t:+ico aocL Pv:~ tests {or btsc lostlrt'
FOR EACH PARTY SERVED YOU MUST ASSESS TH APPROPRIATE NUMBER F COPIES OF THE DOCUMENT TO
BE SERVED * UNLESS CLERK IS TO EMAIL, THEN NO COPY FEE IS REQUIRED*
Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
By ________ Deputy
BW
TYPE OF SERVICE:
0 POTTER COUNTY SHERIFF *SERVICE FEE AND COPY FEE REQUIRED*
0 CIVIL PROCESS SERVER-AUTHORIZED PERSON TO PICK-UP: _______________________
0 POSTING *SERVICE FEE AND COPY FEE REQUIRED*
0 PUBLICATION *SERVICE FEE REQUIRED*
0 CERTIFIED MAIL *SERVICE FEE AND COPY FEE REQUIRED*
0 TO BE MAILED TO PARTY REQUESTING SERVICE *SELF ADDRESSED STAMPED ENVELOPE AND/OR POSTAGE
FEE REQUIRED*
N TO BE EMAILED TO PARTY REQUESTING SERVICES-MUST INCLUDE EMAIL ADDRESS
TITLE OF DOCUMENT: Pio.intr~F ~.., ():l~irol tl:+;-tiof"\ o.OO &=1;t"\s -\(;, bi~c los1 7r(
FOR EACH PARTY SERVED YOU MUST ASSESS THE/iPPROPRIATE NUMBER 0 COPIES OF THE DOCUMENT TO
BE SERVED *UNLESS CLERK IS TO EMAIL, THEN NO COPY FEE IS REQUIRED*
pARTY TO BE SERVED: (PLEASE FILL OUT A NEW REQUEST FORM PER PARTY TO BE SERVED)
NAME:~~~~~~~~~~~~~~~~------------------------
Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
By ________ Deputy
BW
TYPE OF SERVICE:
0 POTTER COUNTY SHERIFF *SERVICE FEE AND COPY FEE REQUIRED*
0 CIVIL PROCESS SERVER-AUTHORIZED PERSON TO PICK-UP:----------------------
0 POSTING *SERVICE FEE AND COPY FEE REQUIRED*
0 PUBLICATION *SERVICE FEE REQUIRED*
0 CERTIFIED MAIL *SERVICE FEE AND COPY FEE REQUIRED*
0 TO BE MAILED TOPARTY REQUESTING SERVICE *SELF ADDRESSED STAMPED ENVELOPE AND/OR POSTAGE
FEE REQUIRED*
.[) TO BE EMAILED TOPARTY REQUESTING SERVICES-MUST INCLUDE EMAIL ADDRESS
!_ _!
FILE MARKED DATE OF DOCUMENT TO BE SERVED:
ADDRESS:~~~~~~~~~~~~~~~~~~-------------------