Paul, Attached is the bio you requested. Please let me know if this is not what you are looking for. Also, I met with the engineer for the school. He did say that they have pushed the construction date on the school back to March. With that in mind, below is a revised schedule: August 2009: On-site inspection of the parcel and environmental site assessment of the Property September 2009: Time period for design of intersection, preparation of construction documents (coordinated with Dallas ISD scheduled for school plan completion) October 2009: Date to solicit construction bids; begin removal of existing structure on the Property November 2009: Notify franchise utilities to be relocated (at their expense); continue removal of existing structure and commence site preparation for intersection improvements and new server main on the Property. December 2009: DISD completion date for design for school; continue site preparation on the Property. January 2010: Commence construction of intersection improvements; complete site preparation for new sewer main on the Property. February 2010: Install new Sanitary Sewer Main to serve the New DISD School. (this is a Critical Item/Milestone) (The new sewer main will be in the same location on the Property as the existing gas station building) March 2010: Commence construction of DISD school August 2011: Complete DISD school (anticipated date to open school) August 2011: Completion of construction of intersection improvements If you have any questions or need any additional information, please feel free to contact me. Thanks, Clay Barnett, P.E. Town Engineer Town of Addison 16801 Westgrove Drive Addison, TX 75001-2818 Office: (972) 450-2857 P Please consider the environment before printing this email. -----Original Message----- From: Dalton, Paul [mailto:pdalton@cowlesthompson.com] Sent: Tuesday, July 28, 2009 2:51 PM To: Clay Barnett Cc: Ext_mail John Hill Subject: Crimson Tide THIS IS A CONFIDENTIAL COMMUNICATION No Privilege Is Waived Or Released Unauthorized Use, Access, or Distribution Is Unconditionally Prohibited. IF YOU ARE NOT THE INTENDED RECIPIENT: 1. Please "Reply" immediately advising of this misdelivery; 2. Delete from your systems all instances of this message; and 3. DO NOT READ ANYTHING BELOW THIS LINE. Clay - As you know, I'm working with John Hill to try to get a court to let the Town onto the Crimson Tide property, for which we believe your affidavit will help convince the judge to order that they must let us on the property. To get such an order, we must show the court how irreparable harm will result if we do not get onto the property soon, and that's why John had asked you for the schedule and why I was earlier collecting info about your status and background as a P.E.. I still need a bit more info about your background for the affidavit. In case it might help you get an idea of what I wanted about your background, here's a paragraph I clipped from a physician's affidavit. Your background information may or may not be as long as his, but that doesn't matter -- we just need for the judge to be able to recognize that you are qualified as an engineer to render opinions about the nature of work the Town must do and the schedule for when that work must be done to facilitate construction and opening of the new school. This background stuff is just part of all that. In 1968, I graduated from the University of Texas Southwestern Medical School in Dallas, Texas as a Medical Doctor and, in that same year, I was licensed as an M.D. by the Texas Board of Medical Examiners. In 1969 and 1970, I performed an internship at Grady Memorial Hospital in Atlanta, Georgia. From 1970 to 1971, I performed a residency in general surgery at Mount Sinai Hospital in Miami, Florida. From 1971 to 1972, I performed a residency in general surgery at Charity Hospital in New Orleans, Louisiana. From 1972 to 1973, I performed a fellowship in plastic and reconstructive surgery at University of Texas Southwestern Medical School in Dallas, Texas. From 1973 to 1975, I performed a residency in plastic and reconstructive surgery at the University of Texas Southwestern Medical School in Dallas, Texas. From 1974 to 1975, I was chief resident in plastic and reconstructive surgery at the University of Texas Southwestern Medical School at Dallas. I have been certified by the American Board of Plastic Surgery since May 7, 1976. I am a member of the Texas Society of Plastic Surgeons, the American Society of Plastic and Reconstructive Surgeons, the American Medical Association, the American Society for Aesthetic Plastic Surgery, the American Association of Hand Surgeons, the Texas Medical Society, I am a Diplomat of the American Board of Plastic Surgery, and a Diplomat of the International College of Surgeons I have attached a preliminary draft of the entire affidavit for you to review that includes the above paragraph in the document as a "place holder" -- you can just edit it there & send it all back, if it's convenient. Let me know if the information I've placed into this affidavit is correct; or, if not, how it should be changed to be correct. By sending this text, I'm not trying to get you to say anything that is not true -- actually, it's intended as a starting place that I hope you can re-word to accurately state how the Town's schedule was developed and to support why it's critically important the Town be allowed to get onto the Property ASAP. - Paul D. Paul Dalton ________________________ COWLES & THOMPSON 901 Main St., Suite 3900, Dallas, TX 75202 214.672.2112 (t) | pdalton@cowlesthompson.com 214.672.2312 (f) | www.cowlesthompson.com