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Strasburger Letter to Rees and Invoice

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Robert Witte of Strasburger & Price letter to Christian Rees and invoice to Dallas Police and Fire Pension System.

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December 3,2012
ROBERT J wrrrs
(214) 651-4612
Direct Fax (214) 659-4089
Robert [email protected]
Board Certi fied Law
Texas Board 01Legal Specialization
Scott Sullivan, Dean
College of Fine Arts
Texas Christian University
via [email protected]
Frances Colpitt. Chair via f.co/[email protected]
Department of Art and Art History
Texas Christian University
Good afternoon.
As a professional courtesy, we wanted to provide you a copy of the attached
correspondence. We hope that it has the desired positive effect, so all involved can
move forward and put this issue behind them. We value the role TCU plays in the North
Texas region , and wish you continued success.
RJW; ct
Enclosure
cc:
Dr. Victor J . Boschlni, Jr.
Chancellor
Brian G. Gutierrez
Vice Chancellor for Finance
and Administration
4421999. 1iSFiW5 16101661120312
via chancel/[email protected] and [email protected]
via [email protected]
Strasburger
,\'1' LAW
November 30, 2012
ROBERT J. wrrra
(214)651-4612
Direct Fax (214) 659-4089
Robert [email protected]
VIA CERTIFIED MA1L#71791000164915991800
Christina E. Rees
Dallas, TX 75218
Dear Ms. Rees:
This firm represents the Dallas Police and Fire Pension System, owner of Museum
Tower.
Our client has worked diligently and in good faith for more than a year to find a mutually
acceptable, scientifically and commercially sound solution to the reflective light issue
involving the Nasher Sculpture Center, and to encourage Nasher representatives to join
in a collaborative effort to work together towards a practical and effective resolution of
this matter. We have utilized highly qualified engineers and scientists to explore, test
and develop potential workable and viable means to achieve this paramount goal.
We have in hand copies of several harassing and disparaging comments and
statements that you have posted online about Museum Tower , the Dallas Police and
Fire Pension System and Barbara Buzzell, including those on both yours and Ms.
'Buzzell' s Facebook pages: 'Ms. 'Buzzell, as you know, owns the public relaflonsflrm.
The Buzzell Company. Her highly regarded firm handles public relattons for Museum
Tower among many other fine clients. She was engaged by our client, as I am sure she
is by others, due to her excellent reputation, unwavering ethical standards and sterling
character.
Please note that your recent Facebook posts have crossed the line, going beyond the
realm of protected free speech into unlawful and legally actionable harassment,
defamation, tortuous interference, and business disparagement. These unfawful
statements and others like them can subject you to significant financial liability for the
damages that they cause. For example, should your unlawful comments result in
someone backing out of an actual or prospective contract to purchase a
condominium at Museum Tower, the resulting judgment against you could take decades
to pay. Further, given that you appear to comment at times in both a personal and
professional capacity, such improper conduct threatens to expose your employer, Texas
Christian University, to liability as well.
4416024.21SPI18516101661113012
Strasburger & Price, LLP
gal Main Street, Suite 4400 I Dallas, Texas 75202.3794 I 214.651.4300 tel I 214.651.4:330 fax I www.strasburger.com
Austin I ('ollin County I [lall". I H""SI'''' I Sun Antonio I New York I Wo"hinKlon. D.C. I Mexico Cit)' - Strasburger & Price, SC
Christina E. Rees
November 30.2012
Page 2
As Museum Tower works towards identifying real and practical solutions to the issues
involving reflected sunlight, we respect the right all citizens have to lawful free speech.
Many Dallas Police and Fire Pension System members have fought to protect that right,
and continue to do so. We simply ask that you immediately remove all unlawful
comments and statements that you have posted online, and cease and desist from any
such behavior in the future. Should you refuse, we will take appropriate action to seek
redress for the damages you cause.
Thank you for your attention to this rna r. Best wishes this Holiday Season.
cc: Scott Sullivan, Dean
College of Fine Arts
Texas Christian University
Frances Col pitt. Chair
Department of Art and Art History
Texas Christian University
4410024.2ISP'16516/01661113012
STRASBURGER & PRICE, L.L.P.
ATTORNEYS AND COUNSELORS
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS'
P.O . BO X 50100
DALLAS. TEXAS 75250·9989
Phone: 214i651-43OO
Dallas Police and Fire Pension system
Attn: Mike Taylor
4100 Harry Hines Boulevard, Suite 100
Dallas, TX 75219
RE: Arts District/Museum Tower
TIN: 75-0038800
January 17, 2013
C/M: 18516.0166
INVOICE NO. 649692
GL1
PAGE 1
FOR PROFESSIONAL SERVICES RENDERED THRU 12/31/12 $ 20,555.00
DISBURSEMENTS THRU 12/31/12 $ 39,731.16
TOTAL AMOUNT DUE $ 60,286 .16
NAME RECAP
INIT NAME RATE HOURS AMOUNT
JT John Tang 435.00 3.00 1 , 305 . 00
CMH Charles M. Hosch 550.00 1. 50 825.00
PS Paul Sander 475.0 0 5.00 2,37 5.00
GL1 Gary Lawson 475.00 18. 50 8 , 78 7. 50
RW1 Robert Witte 450.00 2 . 75 1, 237.50
GF Gus Fields 475.00 1. 50 712.50
MCC Martha C. Coleman 40 0.00 13 . 00 5, 200.00
DK Dana Knollenberg 22 5 .00 0 . 50 112 .50
TOTAL 45.75 $2 0,555. 00
CURRENT AMOUNT DUE SUMMARY SECTION
CURRENT FEES
CURRENT DISBURSEMENTS
CURRENT TOTAL DUE
$
$
$
20,555.00
39,731.16
60,286 .16
STRASBUR GER & PRICE, L.L.P.
ATTORNEYS AND COUNSELORS
Dal l a s PoJ.i ce a nd Fire Pensi on Sys t em
ITEMIZED SERVICES BILL
J anua ry 17, 20 13
C/ 1'1 : 18516.0166
INVOI CE NO . 64 9692
GL1
PAGE 2
MCC
DATE
12 / 02/12
12/02/12
12/03/12
12/03/12
12/03/12
12/03/12
12/04/12
DESCRIPTION NAME
Review of changes to bylaws, rules and PS
regulations and declarati on for
condominium association.
Review letters appearing in Dallas Morning RWl
News (including one submission from Harlan
Crow) regarding Museum Tower matter. (.25
@ No Charge)
Telephone conference with .
regarding finishout contract and
completion of main contract.
Review and analysis of draft fo rm lease. PS
Forward copy of correspondence regarding RW1
Christina Rees to various TCU officials;
communications with Gary Lawson and Josh
Mond regarding pending issues.
Letter to Scott SUllivan, Dean of TCU I s RWI
College of Fine Arts and Frances Colpitt,
Chair of TCU's Department of Art and Art
Hist ory with copies to Dr. Victor
Boschini, Jr., Chancellor of TCU and Brian
G. Gutierrez, Vic e Chancellor for Finance
and Administration regarding client's
concerns with Christina Rees' harassing
and disparaging comments and statement s
she posted online about Museum Tower;
conference with Tate Hemingson regarding
postings.
Start revi ew of comments on agreement with GLI
:;> i. : .: from their lawyer and email quick
reply.
HOURS
0.75
0.00
0.50
0.50
0.50
0.50
0.25
12/04/12
12/04/12
Te lephone conference with and
Ms. Wu r ega rding t enant finish out
contract.
Te lephone conference with TCU counsel Bob
Ginsberg r egarding Christina Rees; u p d a ~ e
telephone c on f e renc e with Gary Lawson a nd
Josh Mond.
STRASBURGER & PRICE, L.L.P.
ATTORNEYS ANO COUNSELORS
Mec
mE
0.75
0.50
Dallas Police and Fire Pensi on Syst em
January 17 ,
C/t1 : 18516 .0166
INVOICE NO. 649692
GLI
PAGE 3
DATE
12/ 04/12
12/05/12
12/05/12
12/06/12
12 / 0 6/ 12
12/0 6/ 1 2
1 2 / 07 / 12
12 / 07 / 12
12/ 07 / 12
12 / 07 / 12
12/10/12
DESCRIPTION NAME
Te l e p hon e conference wi t h Bob Ginsberg of RWl
the fi rm of McDona ld, Sanders, counsel for
Texas Christian University regarding
correspondence directed to Teu regarding
Christina Rees.
Review and analysis in full of amended and PS
restated declaration, bylaws and rules;
complete revi e w of f o rm l e as e.
Review Jeremy Strick 's most recent RW1
comments regarding Museum Tower
multiple discussions regarding upcoming
meeting in Open Records matter with Dallas
Norning News.
Re v i ew email to GL1
and d raft my own follow-up ema il
to same.
Revise contract for finish out work; email Nec
to J o s h Mond regarding same.
Email comments regarding amended and PS
r e s t a ted documents; review a n d analysis of
r e s p onses from J e a nne Katz.
preparation of Certificate of Formation DK
for DDTL, LLC; submit same for filing with
the Delaware Secretary of State.
Meet with Gary Lawson regarding type of GF
entity; discuss Section 552.144 of the
Te x a s Gove r nment Code and 17 CFR
230 .144 (a) (3) .
/
Confer with Gus Fields on tax issue; GLl
emails with Josh Nond on creation of new
LLC for investment in technology .
Review and respond to additional comments PS
f r om Jeanne Katz; attention to fo rmation
of DDTL, LLC; review and revise
certificate .
Conference call with GLl
regarding
HOUHS
0 .25
1. 50
0 .50
0.75
1. 7 5
0 . 75
0.50
1. 5 0
1. 00
0 .75
0 . 75
12/10/12 Draft assignment agreement
a n d ema il to J oh n Ta ng for his input;
c r e a t e n e w ent ity DDTL LLC.
STRAS BURGE R & PRI CE , L.L.P.
AT TORN EYS AN D COU NS EL O RS
GLI 2 .75
Dallas Police and Fire Pension System
January 17, 2013
e/M: 18516.0166
INVOICE NO. 64 9 692
GL1
PAGE 4
DATE
12/10/12
12/1 0/] 2
DESCRIPTION
Various emai1s with Joshua Mond, JT
conference with Gary Lawson, prepare draft
patent assignment regarding
Conference call regarding finish out MCC
contract.
HOURS
1. 00
1. 25
12/10/12 Communications regarding practical
considerations associated with
communications with
consultants.
RWI 0.50
12/11/12
12/11/12
12/11/12
12/12/12
12/12/12
12/12/12
12/13/12
12/ 1 4/ 12
Work on .:.::;:.: agreement edits; GLI
draft confidenti ality agreement as well
and email both to Josh Mond. (2. 00
discounted t o 1.50)
Discuss matt er with Gary Lawson, JT
perform 'p a t e n t search.
Revised finish out contract; email to Mr. MCC
Mond, Ms. Nu, Ms. Iverson and
regarding same.
Conference call with Josh Mond and then GLI
John Tang regarding company and
'" , etc.
Tend to voice mail from JT
discuss same with Gary Lawson.
Attention to emails regarding insurance MCC
plan; revised finish out contract to
reflect insurance issues.
Review the draft video on MT move-in and GLl
suggest modificati ons to same.
Communi cations amails with GLI
regarding
; email from and to
regarding confidentiality a nd
scope of work of e t a I . a t
Te x a s A&M .
1. 50
1. DO
0.75
0 . 75
0. 25
1. 25
0.50
1. 00
12 / 1 4 / 12
12/17/12
Attention t o s mails rega r ding cove r age
fo r t h e fi ni sh out wor k .
Re vi ew and sug g es t edits t o the
:'.", ..: '."/'0 ' ; .. : J:': and send same to
MCC
GLI
0.50
0 . 7 5
:- .'
· r
,'.
; .
12/18/12 Re v .i.ew and revise subs tantial complet ion
certificate .
STRASBURGER & PRICE, L.L.P.
ATTORNEYS AND COUNS ELORS
MCC 0 . 75
Dallas Po l i c e a nd Fire Pens i on System
1 7 , 2013
e l M: 185 16 . 01 66
I NVOI CE NO. 649692
GLI
PAGE 5
DATE
12/19 /12
DESCRIPTION
Confer with Gary Lawson regarding
background and intellectual property
issues related to use of
NAME
CNH
HOURS
1. 50
12/19/12
f and
followed up s ubstantively with Ga ry La ws o n
accordi ngl y .
Meeting at System's offi ces; confer with
Charles Hosch; meeting with ..:>
his colleagues and :j/:'?
GLl 3.00
12/19/12 Email regarding performing renovation work
under main contract instead of pursuant t o
the Letter Agreement; c onference call
regarding same.
MCC 1. 50
1. 25 GLI Telephone conference with
as requested by Richa rd Tett amant;
t e lephone call to
,
; telep hone
call with Josh Mond regarding c onversation
with
12/20/12
12/20/12
12/20/12
Revise Letter Agreement to reflect new
insurance plan; reviewed main contract
regarding insurance provisions; reviewed
insurance provisions drafted by Scott
Whiteside; email regarding same.
Preparation of form
MCC
PS
1. 50
0.75
0.25
2.50 MCC
v ,
to Richard GL1 a nd
.,;, ... .;
Email from and to
Tettamant r e ga r d i ng the
Revised letter a g r e ement to defe r
insurance considerations; attention to
email with Austinls requested edits;
telephone conference with Ms. Iverson
regarding same; revised letter agreement;
emai l to K addressing Austin 's
12/21/12
12/21/12
12/24/12
issues.
Conference call with
discussing the
etc .; draft edits to
- ,
. . ....
. .
.' GLI 1. 00
' ,'
'.
STRASBURGER & PRICE, L.L.P.
ATTORNEYS AND COUNSEl-ORS
Dallas Police and fire Pension System
January 17, 2013
C/H: 18516.0166
INVOICE NO. 649692
GL1
PAGE 6
Telephone call with GLI
telephone call with John Tang and then
phone call with .: ,: . .
. and John Tang; draft
confidentiality and investment exhibit and
send draft to "::-
Teleconference with; . ,,"'.' .; , and Gary JT
Lawson regarding review and
revise email to client summarizing
teleconference.
DATE
12/27/12
12/27/12
DATE
10/30/2012
11/30/2012
12/11/2012
12/19/2012
12/31/2012
DESCRIPTION
TOTAL FOR SERVI CES
ITEMIZED DISBURSEMENT BILL
DESCRIPTION
EXPERTS - .
EXPERTS -
GENERAL RECORDS / REPORTS - CT CORPORATION
COURIER / DELIVERY SERVICE - FED EX
EXPERTS -
TOTAL DISBURSEMENTS
CURRENT AMOUNT DUE SUMMARY SECTION
NAME
$
HOURS
3.00
0.75
20,555.00
AMOUNT
1<1 ,4 97 .50
11,280 .00
738 .00
15. 66
13, 2 00 . 00
$39,731.16
CURRENT FEES
CURRENT DISBURSEMENTS
CURRENT TOTAL DUE
$
$
$
20,555.00
39,731.16
60,286 .16
STRASBURGER & PRICE, L.L.P.
ATTORNEYS ANO COUNSELORS

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