DALLAS COUNTY IS NOTIFIED THAT THE MOOTED REASONS FOR SIX YEARS OF EXPENSIVE DELAY BY THE DALLAS COUNTY E-911 SERVICE BOARD REQUIRE AN HONEST REASON FOR THE DELAY
Hartung & Schroeder
ATTORNEYS AT LAW
EQUITABLE
BUILDING – SUITE 100
PHONE: 515-282-7800
608 LOCUST STREET FAX:
515-282-8700
DES MOINES, IOWA 50309
June 5, 2012
Wayne
Reisetter
Dear Wayne:
As you may be aware, with the promulgation of the 2012 edition of the Official
Dallas County Address Map, the homestead of my client, Carl Hays, has now been
appropriately addressed at 26000 O
Lane . As you are also aware, Mr. Hays
invested considerable time and effort over the course of several years trying
to secure exactly this result. In fact, his first request a proper address
for his property was entered December 15, 2006. Unfortunately, his
requests were wrongfully denied by Dallas
County until very
recently.
Among reasons Dallas
County has given for its
previous denials of this address are:
1.
"Dallas County
cannot change a decision made by the E-911 Board." Pratt ruling on Motion
for Summary Judgment, p.16
2. "…the access point on [sic at] Lane 1 is designated25998 O Avenue ."
Ibid
3. "…it was decided by the E-911 Board that the previous ruling was justified due to the GPS location of said driveway." Ibid P. 20
4. "…due to safety considerations…there would be no further action by the E911 board to grant Mr. Hays' request." Ibid
5. "…the assigned number will be plotted by GPS at the center of the primary entrance of the premises and will not approve multiple addresses to premises." Ibid p. 21
6. "…all of the Plaintiff's [Carl Hays] utility and postal services were established at another address." Ibid p. 22
7. "Plaintiff did not use that particular drive to access his property." Ibid
8. "…the Board felt that the entrances were properly marked." Ibid P. 23
9. "…it is undisputed that Plaintiff already had two separate E911 addresses assigned to his property as a whole at the time the amended ordinance took effect." Ibid P. 59
10. "…it was rational for the Board to deny his requests on the basis that Plaintiff had already been assigned two separate E911 addresses." P 59
11. "24002
260th Street is a nonexistent
address." Ibid P. 60
2. "…the access point on [sic at] Lane 1 is designated
3. "…it was decided by the E-911 Board that the previous ruling was justified due to the GPS location of said driveway." Ibid P. 20
4. "…due to safety considerations…there would be no further action by the E911 board to grant Mr. Hays' request." Ibid
5. "…the assigned number will be plotted by GPS at the center of the primary entrance of the premises and will not approve multiple addresses to premises." Ibid p. 21
6. "…all of the Plaintiff's [Carl Hays] utility and postal services were established at another address." Ibid p. 22
7. "Plaintiff did not use that particular drive to access his property." Ibid
8. "…the Board felt that the entrances were properly marked." Ibid P. 23
9. "…it is undisputed that Plaintiff already had two separate E911 addresses assigned to his property as a whole at the time the amended ordinance took effect." Ibid P. 59
10. "…it was rational for the Board to deny his requests on the basis that Plaintiff had already been assigned two separate E911 addresses." P 59
11. "
With the addressing of 26000 O
Lane , it is now established that all the various
reasons offered by Dallas
County over the years for
its failure to address Mr. Hays' homestead properly were not valid or
prohibitive reasons. Dallas
County could have -- and
eventually did -- grant Mr. Hays the relief he requested, and to which he was
entitled.
Mr. Hays now requests a response from Dallas County
regarding the reason for this completely unnecessary delay and his incurring of
tens of thousands of dollars in legal fees to accomplish what should have been
done in 2006 when first requested.
Thank you. I look forward to your reply.
Sincerely,
Brad
Schroeder
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