Filed

BW Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
106315-D-CV Potter County, Texas
By ________ Deputy
CAUSE NO. _ _ _ _ __

CITY OF AMARILLO, TEXAS IN THE DISTRICT COURT

Plaintiff
320th

vs. - - JUDICIAL DISTRICT

BRANDT ENGINEERS GROUP,
LTD.; L.A. FULLER & SONS
CONSTRUCTION, LTD.; and
MISSION CLAY PRODUCTS
LLC

Defendants POTTER COUNTY, TEXAS

PLAINTIFF'S ORIGINAL PETITION AND REQUESTS FOR DISCLOSURE

Plaintiff City of Amarillo files this Original Petition against Defendants Brandt

Engineers Group, Ltd. ("Brandt"), L.A. Fuller & Sons Construction, Ltd. ("Fuller"), and

Mission Clay Products LLC ("MCP") and shows as follows:

I. DISCOVERY CONTROL PLAN

1. Pursuant to Rule 190.4 of the Texas Rules of Civil Procedure, discovery is

intended to be conducted in the above-styled and numbered cause under Level3, as defined

in Rule 190.3 of the Texas Rules of Civil Procedure.

II. RULE 47 STATEMENT

2. The City of Amarillo seeks monetary relief over $1,000,0000.

III. JURISDICTION AND VENUE

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

occurred in Potter County.

4. This Court has jurisdiction because the amount in controversy is within the

jurisdictional limits ofthis Court.

IV. PARTIES

5. Plaintiff City of Amarillo is a home-rule municipality incorporated under the

authority of the Constitution and laws of the State of Texas.

6. Defendant Brandt Engineers Group, Ltd. is a domestic for-profit limited

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.

7. Defendant L.A. Fuller & Sons Construction, Ltd. is a domestic for-profit

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,

Amarillo, Texas 79108.

8. Defendant Mission Clay Products LLC is a foreign for-profit limited liability

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.

Plaintiff's Original Petition and Requests for Disclosure Page 2

 Code 17.044(a)(l). Mission Clay Products LLC may be served at its home or home

office at P.O. Box 1839, Corona, California 92879 (mailing address) or 708 South

Temescal, Suite 101, Corona, California 92879 (physical address).

V. THE PROJECT AND PROPERTY DAMAGES

9. Plaintiff contracted with Brandt to design and Fuller to construct a sanitary

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,

cracks, fractures, and other structural failures at various locations. Subsequent

investigations by the City of Amarillo revealed numerous defects in the manufacture,

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

condition have contributed to perpetual premature deterioration of the pipe at numerous

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

Plaintiff's Original Petition and Requests for Disclosure Page 3

collapsed. As a result of this ongoing property damage, the City of Amarillo has been

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,

including, without limitation, soils adjacent to the Project.

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.

VI. CAUSES OF ACTION

Brandt- Breach of Contract

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,

including, without limitation, by specifying an inadequate and inappropriate vitrified-clay

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

diligence normally employed by professional engineers performing the same or similar

Plaintiff's Original Petition and Requests for Disclosure Page4

 services at the time and location said services are performed. Brandt did not comply with

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

damages resulting from Brandt's breach of contract.

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

into this Petition.

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

or omissions proximately caused damage to the City of Amarillo's property.

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

into this Petition.

Plaintiff's Original Petition and Requests for Disclosure Page 5

Brandt- Negligent Misrepresentation

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

misrepresentation proximately caused injury and damage to the City of Amarillo.

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

into this Petition.

Fuller -Breach of Contract

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.

Plaintiff's Original Petition and Requests for Disclosure Page 6

 23. Fuller did not comply with the provisions in its contract. Fuller'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 damages resulting from Fuller's breach of contract.

Fuller- Breach of Warranty (Express and Implied)

24. The City incorporates paragraphs 1-23 as if fully set forth here.

25. Fuller expressly warranted to provide a completed project of high quality,

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

consequential damages resulting from Fuller's breach of contract.

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

Plaintiff's Original Petition and Requests for Disclosure Page 7

 om1sswns constituted negligence, and those acts and om1sswns proximately caused

damage to the City of Amarillo's property.

MCP- Product Liability

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

of Amarillo's other property, including, without limitation, contamination or inevitable

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

applicable to its use.

30. MCP breached the implied warranty of merchantability under Chapter 2 of

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

of suitable replacement pipe, and remediation of surrounding property damaged by the

pipe's failure.

31. MCP negligently manufactured and marketed defective vitrified-clay pipe

provided to the Project, resulting in the structural failure of the Project and causing damage

to other property nearby the Project, including, without limitation, contamination or

Plaintiff's Original Petition and Requests for Disclosure Page 8

inevitable contamination of adjacent soils and street damage caused by subsidence of soils

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,

installation of suitable replacement pipe, and remediation of surrounding property

damaged by the pipe's failure. The City of Amarillo seeks direct and consequential

damages against MCP.

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.

VII. CONDITIONS PRECEDENT

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

stated above have been performed or have occurred.

VIII. DAMAGES AND ATTORNEY'S FEES

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

and throughout all stages of appeal.

Plaintiff's Original Petition and Requests for Disclosure Page 9

 IX. JURY DEMAND

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.

X. REQUESTS FOR DISCLOSURE

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

194.2(a)- (i) and 194.2(1).

XI. PRAYER

WHEREFORE, Plaintiff requests that Defendants be cited to appear and answer and

that upon final trial of this matter:

1. Plaintiff have judgment against Defendants for its damages;

2. Plaintiff recovers pre-judgment and post-judgment interest against

Defendants as provided by law;

3. Plaintiff recovers its attorneys' fees and costs of suit through trial and any

appeal against Defendants; and

4. Plaintiff has such other relief as may be just in law or equity.

Respectfully submitted,

ALLENSWORTH & PORTER, L.L.P.

100 Congress Avenue, Suite 700
Austin, Texas 78701
(512) 708-1250 Telephone
(512) 1 Facsimile

Plaintiffs Original Petition and Requests for Disclosure Page 10

 State Bar No. 24059721
ame@aaplaw.com
Will W. Allensworth
State Bar No. 24073843
wwa@aaplaw.com
Kaleb S. Walker
State Bar No. 24098568
ksw@aaplaw.com

-and-

MARTIN W. DIES ATTORNEYS, PLLC

1009 West Green A venue
Orange, Texas 77630-5619
(409) 883-4394
(409) 883-4814 (Fax)

By:
Martin W. Dies
State Bar No. 05853800
mwdies@dieshile.com

-and-

YOUNG & NEWSOM, PC

Tim Newsom
State Bar No. 00784677
tim@youngfirm.com
1001 S. Harrison Street, Suite 200
Amarillo, Texas 79101
(806) 331-1800 Telephone
(806) 398-9095 Facsimile

ATTORNEYS FOR PLAINTIFF

Plaintiff's Original Petition and Requests for Disclosure Page 11

 CERTIFICATE OF MERIT AFFIDAVIT OF LORI COX
PURSUANT TO TEX. CIV. PRAC. & REM. CODE CHAPTER 150
'
STATEOF~

COUNTY OF lA~

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

true and correct.

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

are all true and correct.

2. "I hold a Bachelor Degree in Civil Engineering from the University of

Kentucky, and a Bachelor Degree in Applied Mathematics from Kentucky State

University. I am a registered Professional Engineer duly licensed in the State of Texas

since 2010, and am actively engaged in the practice of engineering in Texas. My Texas

professional engineering registration number is 106836. I have over 17 years experience

in the practice of civil and structural engineering, including in the areas of forensic

analysis, design, construction administration, field investigation, and project

management. A copy of my curriculum vitae is attached and incorporated as Exhibit A.

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

Certificate of Merit Affidavit of Lori Cox

1
Page 1
 Consulting Services Agreement between City of Amarillo and Brandt

Engineers Group, Ltd. ("Brandt Engineers") for the Sanitary Sewer Main

Extension Section 64, Block 9, B.S.&F Survey ("the Project");

April 2006 construction documents for the Project, sealed by Dwight L.

Brandt;

The Project' s plans and specifications;

ASTM C12-07; ASTM C301-04; ASTM C700-05; The 2003 and 2005

versions of The Greenbook of Standard Specifications for Public Works;

ASCE Manuals and Reports on Engineering Practice No. 60- Gravity

Sanitary Sewer Design and Construction; Vitrified Clay Pipe Engineering

Manual; Technical paper Septicity in Sewers: Causes, Consequences and

Containment by A. G. Noon; National Research Council of Canada paper

Condition Assessment and Rehabilitation of Large Sewers, by McDonald

and Zhao; Environmental Protection Agency Report to Congress 430/09-

91-010 September 1991 Hydrogen Sulfide Corrosion In Wastewater

Collection and Treatment Systems technical report;

Email correspondence between Jeff Boschert, P.E. and Dwight Brandt;

Preliminary Engineering Report Hillside Terrace Estates 30" Sewer

Replacement by CH2M;

Inspection on September 21 , 2016, of various locations of the installed

sanitary sewer system, observation ofthe excavation of the backfill material

used atop the pipes, observation of the pipe in situ and the bedding

Certificate of Merit Affidavit of Lori Cox Page2

 materials, observation of the fractures of the top of the pipe uncovered

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

fractured and delaminated condition of said pipe;

In addition, communications with other Rimkus employees that were on

site and provided information regarding their observations on site;

Communications with Ron Reed and Darren Williams of Reed Engineering

regarding the observed bedding conditions;

4. "I am familiar with the Consulting Services Agreement between Brandt

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

normally employed by professional consultants performing the same or similar services

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

services not meeting that standard of care.

5. "Based on my review of the Project's plans and specifications, Dwight L.

Brandt with Brandt Engineers sealed the Project' s construction drawings and

specifications. I visited the Texas Board of Professional Engineers webpage and

confirmed that Mr. Brandt is a registered engineer in Texas (Professional Reg. No.

Certificate of Merit Affidavit of Lori Cox Page 3

48280). The Texas Board of Professional Engineers' webpage lists Brandt Engineers as

Mr. Brandt's employer.

6. "Based on my education and professional experience, I have personal

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

knowledgeable in the area of practice performed by Brandt Engineers and Dwight L.

Brandt, which included sanitary sewage collection system design, and administration and

observation of the construction of sanitary sewage collection systems.

7. "Based on information and belief, my review of the terms of the Consulting

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

Occupations Code 1001.003(c). Based on my review of documents, my observations at

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

fail. It is my opinion, based on my knowledge, skill, experience, education, training, and

engineering practice that Brandt Engineers and Dwight L. Brandt negligently breached

the duty of reasonable care for engineers imposed by the Consulting Services Agreement

and by law, in at least the following ways:

1. By specifying vitrified clay p1pe (VCP) for use in a sanitary sewer,

particularly at the depths prescribed, without requiring sufficient testing as

Certificate of Merit Affidavit of Lori Cox Page 4

 required by the ASTM standards and failing to ensure and confirm that

testing was performed. Sanitary sewers are well known for their highly

corrosive nature. To not specify the pipe being used in a corrosive

environment pass an ASTM test set to establish its resistance to such a

condition is negligent. The delamination observed along the top of the

pipe was consistent with the effects of hydrogen sulfide gas on the pipe.

Hydrogen sulfide gas is naturally created within the sanitary sewer systems

and is an expected problem.

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

more suited for an application of this type.

Proper performance of VCP is also dependent upon installation methods.

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.

2. Bedding of the VCP is extremely critical, particularly at the depths of this

installation. The manner of pipe embedment and the type of aggregate

Certificate of Merit Affidavit of Lori Cox Page 5

 used is critical to disperse the overburden (backfill) loading acting on the

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

in the lines and failure. VCP requires additional attention during

installation to ensure the bedding material properly supports that pipe and

redistributes the weight of the overburden/backfill. Without this, VCP is

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

susceptible to high shrink/swell. High shrink/swell are soils properties that

are inherently affected by moisture content. At the depths of this sewer

line, the failure of the pipe and subsequent introduction of additional

moisture to the soils supporting the bedding exacerbated the movement and

failure of the pipe.

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

Certificate of Merit Affidavit of Lori Cox Page6

 material compacted to 95% standard proctor density. When the VCP was

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

soils. Any prudent engineer performing construction administration

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

contract documents. This was not done. As a result, the

overburden/backfill loading was directly atop the VCP and not properly

distributed around the pipe.

8. "Brandt Engineers and Dwight L. Brandt were responsible for designing

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

Project's sanitary sewer pipeline and related damages.

Certificate of Merit Affidavit of Lori Cox Page 7

 9. "This affidavit is not intended to be an all-inclusive list of each error,

omission, or negligent act of Brandt Engineers or Dwight L. Brandt. It is intended only

to comply with the applicable Certificate of Merit statutes, if any. I reserve my right to

amend my professional opinions and to form additional ones as more information

becomes available to me."

FURTHER AFFIANT SA YETH NOT.

Lori L. Cox, P .E.

Notary Public, State ofT~~~

My Commission Expires:
MALIA L. STORRER
Marion County
My Commission Expires
January 24, 2024

Certificate of Merit Affidavit of Lori Cox Page 8

 LORI L. COX, P.E.
DISTRICT MANAGER
Ms. Cox graduated from the University of Kentucky in 1995 with a Bachelor of Science Degree
in Civil Engineering. She also graduated from Kentucky State University in 1995 with a
Bachelor of Science Degree in Applied Mathematics and Bluegrass Community Technical
School as a Nationally Certified Emergency Medical Technician. She has over 20 years of
structural engineering experience. She is registered as a Professional Engineer in 30 states
including Alabama, Arizona, California, Connecticut, Delaware, Florida, Georgia, Hawaii, Illinois,
Indiana, Kentucky, Louisiana, Maryland, Michigan, Mississippi, Missouri, Nevada, New
Hampshire, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, South Carolina,
Tennessee, Texas, Virginia, Vermont, Washington and Wisconsin. Ms. Cox has engineering
consulting experience in various industries including residential, commercial, municipal,
industrial, roadways, agricultural and manufacturing as well as premises liability including
slip/falls, trip/falls and code compliance and construction liability.
Ms. Cox joined Rimkus Consulting Group in August 2011. Over her career, Ms. Cox has
performed thousands of engineering investigations for insurance companies, law firms,
construction firms, and property owners. She has expertise in roadway design and
construction, maintenance of traffic plans (MOT), roadway signage, intersection design and
construction, sight distance, evaluating buildings and structures for various conditions and forms
of damage, including: code compliance, construction defects, premises liability, risk
assessment, moisture intrusion/water damage, structural failure analysis, differential foundation
movement, paving operations, construction vibration and blasting/explosion damage, fire
damage, and earthquake/hurricane/tornado/storm damage. Ms. Cox has testified in federal
court, before jurys and three-judge panels, attended arbitrations, mediations, served as an
umpire and has been deposed over 20 times. She has also given presentations on various
forensic engineering topics to the legal and insurance industry.

EDUCATION AND PROFESSIONAL ASSOCIATIONS

B.S. Civil Engineering University of Kentucky
B.S. Applied Mathematics Kentucky State University
P.E. Registered Professional Engineer AL, AZ, CA, CT, DE, FL, GA, HI, IL, IN, KY, LA, MD,
MI, MO, MS, NV, NH, NC, OH, OR, PA, RI, SC, TN, TX, VA, VT, WA, WI
A.S.C.E. American Society of Civil Engineers (1993 to present)
Nationally Registered Emergency Medical Technician (2008)
HAZWOPPER- 40 hour Hazmat Technician (2008)
English XL VIT CXL Technician (2013)
Certified Walkway Auditor (2014)
Continuing Education Courses and Related Training:
Pre-stressed Concrete Design (Graduate Class) University of Kentucky (1994)
Foundation Design (Graduate Class) University of Kentucky (1994)
Thinking Beyond the Pavement (KY Transportation Research Center -2001)
Structural Condition Assessment of Existing Structures ASCE (Baltimore, MD, 2005)
Composition and Wood Shake Roofs Damage Assessment (Seminar, Dallas, TX, 2001)
Built-up and Membrane Roofs Damage Assessments (Seminar, Dallas, TX, 2001)
Wood Truss Design and Repair Workshop (Virginia Tech, Blacksburg, VA, 2007)
Seismic Loading of Structures (Menlo College, San Jose, CA, 2010)
Level I Technician PFAS Assisted Roof Inspection, ACRABAT (Houston, TX, 2012) EXHIBIT
RIMKUS CONSULTING GROUP, INC. OFFICES NATIONWIDE AND ABROAD A
 LORI L. COX, P.E.

English XL VIT Certification (Philadelphia, PA, 2013)

Walkway Auditor Certification ASTM F2948 FORCON International (Houston, TX 2014)
EMPLOYMENT HISTORY
2011 Present Rimkus Consulting Group, Inc.
2008 2011 PT&C Forensic Consulting Services, LLC
2007 2008 TRC Forensics
2001 2007 EFI Global
1997 2001 Brighton Engineering
1996 1997 Monarch Engineering
1995 1996 HMB Engineering
1994 1995 Commonwealth of Kentucky Transportation Cabinet
1989 1994 Commonwealth of Kentucky Transportation Scholarship
Student

DETAILED PROFESSIONAL EXPERIENCE

RIMKUS CONSULTING GROUP, INC. 2011 - PRESENT

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.

PT&C FORENSIC CONSULTANTS, LLC. 2008 2011

Regional Manager of the West and Southeast Regions

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.

Warehouse roof collapse after rainstorm event in Mississippi.

Structural damage to industrial facility due to chemical explosion in Louisville, Kentucky.
Hail and wind damage assessment to commercial and residential roofs and siding after
large storm in Indianapolis.
Foundation undermining assessment for existing building adjacent to construction site.
Ground vibration damage assessment for existing buildings located near blasting
activities at a construction site in Utah.
Extent of fire damage determination for existing concrete slab foundation system for a
burned retail facility.
Moisture damage assessment for commercial and residential buildings.
Structural assessment of numerous residential structures following tornadoes in
Alabama.
Moisture source assessment for structures with EIFS siding material.
Wind and water damage to numerous residential and commercial structures in Texas
and Louisiana caused by Hurricanes Gustav and Ike (2008).
Earthquake damage assessment for numerous residential buildings in Southern Illinois
and Southern Indiana.
Wood truss collapse for a one-story large livestock facility.
Swimming pool failure investigations in Kentucky, Georgia, Texas and California.
Reviewed cost estimates for large fiber optic line cut during the installation of light rail
bridge piers in Utah.

TRC FORENSICS 2007 - 2008

Regional Manager- Lexington Office

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:

Hail damage assessment to commercial and residential roofs in Indiana and

Kentucky.
Moisture damage assessments for residential structures in Indiana and Kentucky.

EFI GLOBAL 2001 - 2007

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:

Manufacturing facility roof collapse after snow event in Louisville, Kentucky.

Structural damage to lime processing facility in Louisville, Kentucky.
Hail and wind damage assessment to commercial and residential roofs and siding
after large storm in Chicago, Illinois and Indianapolis, Indiana.
Parapet failure on historic theater in Cincinnati, Ohio.
Ground vibration damage assessment for existing buildings located near blasting
activities at a major highway construction site in Versailles, Kentucky.
Extent of fire damage determination for existing foundation system for burned
residential structures.
Moisture damage assessment for commercial and residential buildings, including
HVAC analysis.
Structural assessment of numerous residential structures following tornadoes in
Missouri, Indiana and Kentucky.
Wind damage to gym of a church facility.
Moisture source assessment for structures with EIFS siding material.
Wind and water damage to numerous residential and commercial structures in
Florida, Mississippi, Louisiana and Alabama caused by Hurricanes Charlie, Frances,
Ivan, Jean (2004) Katrina, Rita, Wilma (2005).
Earthquake damage assessment for numerous residential buildings in Western
Kentucky.
Evaluation of exterior stone staircase in a prominent nightlife area in Newport,
Kentucky for slip resistance following several slip/falls.
Evaluation of retail facilities to determine extent of damage following fire suppression
efforts in Gretna, Louisiana.
Determination of cause of near collapse of an elevated water tank in Jackson,
Kentucky.

BRIGHTON ENGINEERING 1997 2001

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.

Bluegrass Industrial Park (Sebree, KY). Designed infrastructure including water,

sewer, roadways, site grading and one million gallon elevated water supply storage
tank for 750 acre industrial park.
Franklin County Industrial Park #3 (Frankfort, KY) Designed infrastructure including
water, sewer, roadways and site grading for 103 acre industrial park expansion.
Oversaw construction of infrastructure.
Kentucky Capitol Executive Office Building (Frankfort, KY) Designed site including
walkways, underground tunnel locations, parking, way-finding, storm water and
grading for proposed Executive Office Building on the grounds of the Kentucky
Capitol.
St. Clair Mall (Frankfort, KY) Designed streetscape including brick pavement for re-
opened pedestrian mall, limestone curbs, separation of sanitary and storm water
conveyance systems, provided ADA access and new sidewalks.
Worked through contract to server as the Franklin County Engineer evaluating
development plans and conformance with regulations.

MONARCH ENGINEERING 1996 1997

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.

HMB ENGINEERS 1995 - 1996

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.

KENTUCKY TRANSPORTATION CABINET 1994 - 1995

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.

KENTUCKY TRANSPORTATION CABINET 1989 - 1994

Transportation Scholarship Student

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.

KENTUCKY TRANSPORTATION RESEACH CENTER 1993 - 1994

Transportation Scholarship Student

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.

SEMINARS FOR CONTINUING EDUCATION PRESENTED BY MS. COX

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

CIVIL CASE INFORMATION SHEET

106315-D-CV
CAUSE NUMBER (FOR CLERK USE ONLY): _ _ _ _ _ _ _ _ _ _ _ _ _ COURT (FOR CLERK USE O N L Y ) : - - - - - - - - - -

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.

Name: Email: Plaintiff(s)/Petitioner(s):

Amy Emerson ame@aaplaw.com City of Amarillo, Texas

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

Probate & Mental Health

Probate/Wills/Intestate Administration 0Guardianship--Adult
0Dependent Administration 0Guardianship--Minor
Olndependent Administration OMental Health
OOther Estate Proceedings Dother: _ _ _ _ _ __

0Declaratory Judgment 0Prejudgment Remedy

0Garnishment 0Protective Order
Olnterpleader 0Receiver
OLicense 0Sequestration
0Mandamus 0Temporary Restraining Order/Injunction
0Post-judgment 0Turnover
Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
Rev 2 13
By ________ Deputy
 ALLENSWORTH & PORTER, L.L.P.
100 Congress Avenue, Suite 700
Austin, Texas 78701

TeleJ?hone: (512) 708-1250

BW Facsimile: (512) 708-0519

AMY M. EMERSON Email Address:

Attorney At Law ame@aaplaw.com

March 23, 2017

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.

Dear Ms. Woodburn:

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.

If you have any questions, please let me know. Thank you.

AME/lkm

Encl.

Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
By ________ Deputy
 BW

REQUEST FOR ISSUANCE

106315-D-CV
CAUSE NUMBER: ----------------

TYPE OF ISSUANCE: *E-FILING-YOU MUST ASSESS THE TYPE OF ISSUANCE,

TYPE OF SERVICE, SERVICE FEES, AND COPY FEES ACCORDINGLY*
lKJ CITATION
0PRECEPT
OTRO
0 PROTECTIVE ORDER
0 ABSTRACT OF JUDGMENT
0 WRIT OF EXECUTION
D OTHER:-------------

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*

FILE MARKED DATE OF DOCUMENT TO BE SERVED: I I

PARTY TO BE SERVED: (PLEASEFILLOUTANEWREQUESTFORMPERPARTYTOBESERVED)

NAME: Bro.ndf 9ioeeii'S C'110LJ~, Lt::/.

ADDRESS: 4537 to.nyoo bdve) ArcUt'illDJ Texo:s 11110

AGENT, IF APPLICABLE: .!,_MJ..l0l!.!.V'-f---"'E.,_,_._.,J?.uva:.Jd.LJrdfU-L-----------------

PARTY/ATTORNEY REQUESTING SERVICE:

NAME: td-j o-f ArtiliC;IjoJ :rexQs r:Jo Amy M. t:Mers<:r)

MAILING ADDRESS: ....,_,_,."'---'..a_-9-"-'"""'--'---'--"IU.L-U.L'""-f--".I'I,LLLI..--f-1..L""':::--"-'-'-t:...l'..l!~---'-"~+--'-4L-.p...l4----

Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
By ________ Deputy
 BW

REQUEST FOR ISSUANCE

106315-D-CV
CAUSE NUMBER: ----------------

TYPE OF ISSUANCE: *E-FILING-YOUMUST ASSESS THE TYPE OF ISSUANCE,

TYPE OF SERVICE, SERVICE FEES, AND COPY FEES ACCORDINGLY*
[:5{J CITATION
0PRECEPT
0TRO
0 PROTECTIVE ORDER
0 ABSTRACT OF JUDGMENT
0 WRIT OF EXECUTION
0 OTHER: _________________

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*

FILE MARKED DATE OF DOCUMENT TO BE SERVED: /_________:/

pARTY TO BE SERVED: (PLEASE FILL OUT A NEW REQUEST FORM PER PARTY TO BE SERVED)
NAME:~~~~~~~~~~~~~~~~------------------------

PARTY/ATTORNEY REQUESTING SERVICE:

NAME:~~~~~~~~~~~~~~~~~~~~-----------------

Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
By ________ Deputy
 BW

REQUEST FOR ISSUANCE

106315-D-CV
CAUSE NUMBER: ---------------

TYPE OF ISSUANCE: *E-FILING-YOU MUST ASSESS THE TYPE OF ISSUANCE,

TYPE OF SERVICE, SERVICE FEES, AND COPY FEES ACCORDINGLY*
gj CITATION
DPRECEPT
DTRO
0 PROTECTIVE ORDER
0 ABSTRACT OF JUDGMENT
0 WRIT OF EXECUTION
D OTHER:-----------------

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

TITLE OF DOCUMENT: J?/Otirri&fs Orl~nnl ft::!'c:xJ goo 16e~~;esk fc:.~ Dlsrk:fiWC

FOR EACH PARTY SERVED YOU MUST ASSESS TH APPROPRIATE NUMBER OF COPIES OF THE DOCUMENT TO
BE SERVED *UNLESS CLERK IS TO EMAIL, THEN NO COPY FEE IS REQUIRED*

!_ _!
FILE MARKED DATE OF DOCUMENT TO BE SERVED:

PARTY TO BE SERVED: (PLEASEFILLOUTANEWREQUESTFORMPERPARTYTOBESERVED)

NAME: M!'SSI,t::r'. t~ 'f?radtJCS J LLC.

ADDRESS:~~~~~~~~~~~~~~~~~~-------------------

AGENT, IF APPLICABLE: "Tf02 Sec::cegvy of 'State

PARTY/ATTORNEY REQUESTING SERVICE:

NAME:~4-~~~~~~~~--~~~~~~~~~~---------------
Filed
Caroline Woodburn
District Clerk
3/23/2017 3:08:35 PM
Potter County, Texas
By ________ Deputy