HomeMy WebLinkAboutO-2008-3092 CLP electing to be included in class action lawsuit for collection of Hotel-Motel taxes from Online Travel Companies
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askins
& askins P.C.
ATTORNEYS and COUNSELORS
Knox W. Askins
Clark T. Askins
July 3, 2008
Hon. Mayor & City Council
City of La Porte
City Hall
La Porte, Texas
Mr. Ron Bottoms
City Manager
City of La Porte
City Hall
La Porte, Texas
Mr. John Joerns
Assistant City Manager
City of La Porte
City Hall
La Porte, Texas
Mr. Michael Dolby
Director of Finance
City of La Porte
City Hall
La Porte, Texas
Re: City of San Antonio, Texas, Et AI, Plaintiff vs Hotels.Com,
L.P., Et AI, Defendants; a Class Action Lawsuit in the United
States District Court, Western District of Texas, San Antonio
Division, in the Nature of a Class Action Lawsuit for the
Collection of Hotel Motel Taxes.
Dear Gentlemen and Ms. Malone:
Each of you will find enclosed with your letter, copy of a letter
which was dated June 25, 2008, from Diamond McCarthy LLP, attorneys
of Dallas, Texas, which explains the nature of this litigation; an
Order on Class Certification which was entered by the Court on May
27, 2008; and a formal notice to the City of La Porte and the other
174 class member cities, entitled "Class Action Notice", which
gives a summary of the proceedings, and the elections which the
City of La Porte must make.
I have carefully reviewed this material, and it is my
recommendation that the City of La Porte exercise Option C, "The
Right to Be Included In or Excluded From the Class", subparagraph
1, "Your City Mav Do Nothinq and Remain a Member of the Class".
702 W. Fairmont Parkway, P.O. Box 1218, La Porte, TX 77572-1218
281.471.1887 phone . 281.471.2047 fax . knoxaskins@comcast.net . ctaskins@swbell.net
City of San Antonio
July 3, 2008
page 2
In my opinion, the City has everything to gain, and nothing to
lose, by participating in the class action litigation. As pointed
out in the notice, the city of La Porte will have no obligation to
pay any of the costs or attorneys fees involved in the litigation
at this time. As in a personal injury lawsuit, if the class
prevails, the Court will award attorneys fees and non taxable
costs, as authorized by law, which will come out of the damages
awarded. On the other hand, if the cities do not prevail in the
lawsuit, the class action attorneys will have to pay these costs.
I have prepared and enclosed a form of ordinance for consideration
by City Council, electing the recommended Option. If City staff
wishes to make a different recommendation, please advise me, and I
will prepare an appropriate ordinance for consideration by City
Council.
Please call me if you have any questions.
y~;;zL
Knox W. Askins
City Attorney
City of La Porte
KWA: sw
Enclosures
cc: Ms. Martha A. Gillett
City Secretary
City of La Porte
City Hall
La Porte, Texas
ORDINANCE NO. 2008~jOq~
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF LA PORTE, ELECTING
TO BE INCLUDED IN A CLASS ACTION LAWSUIT PENDING IN UNITED STATES
DISTRICT COURT, WESTERN DISTRICT OF TEXAS, SAN ANTONIO DIVISION,
FOR THE COLLECTION OF HOTEL-MOTEL TAXES FROM ONLINE TRAVEL
COMPANIES, FINDING COMPLIANCE WITH THE OPEN MEETINGS LAW, AND
PROVIDING AN EFFECTIVE DATE HEREOF.
BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF LA PORTE:
Section 1. The City of La Porte has received a "Class Action
Notice" dated June 30, 2008, in connection with a suit styled City
of San Antonio, Texas, et al, Plaintiff v. Hotels.com, L.P., et al,
Defendants, Case No. SA06CA0381 OG, pending in the united states
District Court, Western District of Texas, San Antonio Division.
After due consideration of the options presented to the City of La
Porte in the "Class Action Notice", the City Council of the City of
La Porte exercises its right to be included in the class of 175
Texas cities constituting the class, and remaining a member of the
class.
Sec tion 2.
The City Council officially finds, determines,
recites, and declares that a sufficient written notice of the date,
hour, place and subject of this meeting of the City Council was
posted at a place convenient to the public at the City Hall of the
City for the time required by law preceding this meeting, as
required by the Open Meetings Law, Chapter 551, Texas Government
Code; and that this meeting has been open to the public as required
by law at all times during which this ordinance and the subject
matter thereof has been discussed, considered and formally acted
upon.
The City Council further ratifies, approves and confirms
such written notice and the contents and posting thereof.
Section 3. This Ordinance shall be effective from and after
its passage and approval, and it is so ordered.
PASSED AND APPROVED, this I~day of July, 2008.
~~.OF .LJ;\ PORTE
~X~
Alton E. Porter, Mayor
By:
ATTEST:
~0tlh1/( \Jf-{UA~~ 7l p.f{ /lU
Ma tha A. Gillett I
City Secretary
APPROVED:
~W
Knox W. Askins
City Attorney
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DIAMOND McCARTHY LLP
Attorneys & Counselors
Renaissance Tower 11201 Elm Street, 34th Floor I Dollos, TX 75270 I Phone: 214.389.5300 I Fox: 214.389.5399
June 25, 2008
Mr. KnoxW. Askins
City Attorney
P.O. Box 1218
La Porte, TX 77572-1218
Re: City of San Antonio, Texas, on Behalf of Itself and All Other Similarly Situated
Texas Cities v. Hotels.com, et a!., Case No. SA06CA0381 OG
Dear Mr. Askins:
On May 27,2008, the Federal District Court for the Western District of Texas certified a
class of 175 Texas cities (including your City) in a suit for damages against certain online travel
companies ("OTCs") - like Hotels.com, Travelocity, Expedia, Priceline.com, Orbitz, and others.
The suit, originally filed May 8, 2006, alleges that the OTCs collect the hotel occupancy tax
from customers at the retail price they charge the customer for the room, but remit the tax based
on the wholesale price they paid the hotel for the room, keeping the difference.
By way of example, an OTC sells a room to a customer for $200.00 and charges a 15%
bed tax or $30.00. It remits the tax based on the $150.00 wholesale price it pays the hotel for the
room - or $22.50 ($150 x 15%), keeping the difference - or $7.50.
A two-day class certification hearing was held on May 16 and May 17,2007. This letter is an
informal notice of the certification order, a copy of which is enclosed, along with the 32-page detailed
OpInIOn.
One of the most significant findings of the Court is on page 4 where the Court writes: "It
is undisputed that Defendants have paid bed taxes to the hotels on the wholesale price of
. the rooms, but they have never paid taxes on the retail price that the consumer pays when
he books a room through a web-based company." That finding is important because it is
contrary to the ordinances of the cities in the class (including your ordinance). Weare in the
process of calculating damages for each city in the class.
As lead counsel for the Plaintiffs, we will mail a formal notice to you and the other class
members shortly.
Please let me know if you have any questions.
With kind regards,
)~Lv~
Steven D. Wolens
Jur~ 2 7 LUlJO
SDW!cs
Enclosures Diamond McCarthy LLP
Austin 16504 Bridgepoint Porkwoy I Suite 400 I Austin, TX 78730 I Phone: 512.617.5200 I Fax: 512.617.5299
Houston I Two Houston Center I 909 Fannin, Suite 1500 I Houston, TX 7701 0 I Phone: 713.333.5100 I Fox: 713333.5199
New York /620 Eighth Avenue, 39th Floor / New York, NY 10018 I Phone: 212.430.5400 I Fax: 212.430.5499
www.diamondmccarthy.com
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UNITED STAT~S DISTRICT C()URT
WESTERN DISTRICT OF tEXAs
SAN ANTONIO DIVISION
FILED
Def~ndants
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Qt..ERK, u.s,
\IIJE$TERN Dl
BY~
CITY OF SAN ANTONIO
Plaintiff
v;
CIVIL NO. SA..06..:CA-38i..OG
HOTELS~COM,etal
Order on Class Certification
PendingbefotetheCourt isPlain1iWs Motion for Cla.ss Certincatit)n CDkt. # 45).
Defendants filed a response (Dkt. # 55, 56) and Plaintiff filed a reply (Dkt#59). Plaintiff
arl1ended its corn plaint (Dkl:. # 74) and then supplemented itsmotionCDkt. #88). TheCourt
detetminedthattUscovety on class certification issues was hecessaty, and. th.e parties ehgagedill
rathetemeljS't've':pre-certificatiohdisQ0very. At the end of the discovery period, Plaintiff filed a
briefin support oflts supplemental motion (Dkt. # 152) and Defendal1tsfiIed their opposition to
Pla.intiff's supplementalmotlon for class certification (Dkt. # 163, 164). Pla.intiff then filed its
second supplementalbriefin support of class certification(Dkt. # 190).
011 May 16~ 17, 2007, the Gourt held an evidentiary hearihg on the motion for class
certification. The Court heardevideJ:1ceand legal arguments from all parties and, in the interest
ofjudicia.l economy; allowed certain evidence to be presented by submission. After the hearing,
Plaintlfffile:dits post-heating brief ili support of its supplemental motion for class certification
([>&1.. #217,218) and Defendants filed their post~heatii1g briefin opposition thereto (D1.1.. # 22(}).
The parties' experts, whotesrifiedat the class certification hearing, were also permitted to
supplement their reports. Their supplemental and rebuttal reports were filed along with the
exhlblts,an~deposi:tion tesHm.ol1.ythatwere',offeredbysubmission.
A;~f heanng,tlIeargtitiIel'ifs..ofeoufisel.'andfhe'evldencepresentetlh'Y.submtssioficafidat
the he.ating,and ,after reviewing the parties' briefs' and the applical)le laVlT> the Court fihds'thcjl
PlailitIffs:motlbn forclasscertinca:tionshouldbe GR.l\.l"fr'Eb for the reasons stated intne
Cburt'smemoratidllmand opinion, flIed Under seal ctHitem.potaneously l1efe\\lftll.
TheCpurt will unseal the Me.m.orandum and Opinion on Class Cettifica:tiG>l1.on June 12,
flO(}S unlessapartytequ.estsaheadtrg and shows good CauSe whythe.bpMOl1 sltoulclremain
sealcQ.... 'I'hernovitrg panysnall. s.UOI11it . a brief'with sufficient authoritY. sUppbrtirigJneif position
pnbrto .t1ll1e 12~2008.
Tne-class frieIllbersafe entitled to natice arid an opportunity to opt out bfthe class.
'Therefare, 'tl1e,Caurtfurther ORDER.S that fhepartiescanferandrepartback fa the C.ourt,within
fel:i(lO)€f4ys ftam'tll.e date beloW, With their recommeridatiol1 on the substantive language to be
in,Ql.1Jd~d:inthe;'notice and parameters .on how and when the class m'Cmbersro.~y elect to opt Qut
of the class. The notice shall comply with the requitements setforthin Fed,R.Clv.F. 23(cD(2)tB).
Plaii1ti.:ff1ia$statedtl1~fa secuiitydeposit to caver the costs of hoticewill hofpe necessaty.
Withinnventy (20) days from the date below, the parties sll.aIlconterandsubmit a
propQsedscheduling for the remainder of these proceedings. If the parties . call11bt reacl1'an
agreement; each side may submit their own proposed scheduling.order and the Court will
COhsidertheparties' suggestions and ehtetan appropriate ardet.
SIGNEp.this .;{? day of May, 2008.
I~<R' ~.
ORLANDO L qAJ~J+~
UNITED STA TESDISTRICT JUDGE
J line 30, 2008
UNITED STATES DISTRlCT COURT
WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION
CITY OF SAN ANTONIO, TEXAS, et a1.,
Defendants.
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CASENO. SA06CA0381 OG
Plaintiff,
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v.
HOTELS.COM, L.P.; et a1.,
CLASS ACTION NOTICE
PLEASE READ TillS NOTICE CAREFULLY - YOUR LEGAL RIGHTS
l\1A Y BE AFFECTED BY A LAWSUIT NOW PENDING IN TillS COURT
TO: The City Attorney for (or other duly authorized representative of) the Cities of Abilene,
Addison, Alice,. Alvin, Amarillo, Angleton, Aransas Pass, Argyle, Austin, Azle, Balch Springs,
Baytown, Beaumont, Bedford, Bellville, Benbrook, Big Spring, Boeme, Borger, Brenham,
Bridge City, Bridgeport, Bryan, Burkburnett, Burleson, Canyon, Carrollton, Castroville, Cedar
Hill, Cedar Park, Clebume, Cleveland, Coleman, College Station, Colleyville, Colombus,
Commerce, Couroe, Coppell, Copperas Cove, Corpus Christi, Corsicana, Dallas, Decatur, Deer
Park, Denton, Desoto, Dickinson, Duncanville, Eagle Pass, Edinburg, El Paso, Euless, Fairview,
fanners Branch, Flatonia, Flower Mound,' Forest Hill, Forney, Fort Stockton, Fort Worth,
Fredricksburg, Friona, Frisco, Gainesville, Garland, Georgetown, Gonzales, Granbury, Grand
Prairie, Grapevine, Greenville, Groves, Haltom City, Harker Heights, Haslet, Hedwig Village,
Henrietta, Hidalgo, Hillsboro, Houston, Humble, Hurst, Ingleside, Irving, Jersey Village,
Junction, Kaufman, Kerrville, Kilgore; Killeen, La Feria, La Marque, La Porte, Lacy-Lakeview,
Lake Dallas, Lake Jackson, Lancaster, Laredo, League City, Lewisville, Lockhart, Longview,
Lorena, Lubbock, Mansfield, Marble Falls, Marshall, McAllen, McKinney, Mesquite, Mexia,
Midland, Mission, Mount Pleasant, Muleshoe, Nacogdoches, Nassau Bay, New Braunfels, North
Richland Hills, Odessa, Palestine, Pasadena, Pearland, Pharr, Port Aransas, Port Arthur, Red
Oak, Richardson, River Oaks, Rockport, Rockwall, Rosenberg, Round Rock, Rowlett, Saginaw,
San Angelo, San Antonio, San Marcos, Sanger, Santa Fe, Schertz, Seabrook, Sealy, Seguin,
Selma, Shenandoah, Shennan, Sonora, South Houston, Stafford, Stephenville, Sugar Land,
Temple, Terrell, Texarkana, Texas City, Tomball, Tyler, Universal City, Victoria, Vidor, Waco,
Watauga, Weatherford, Webster, Weimer, Westlake, Wharton, White Settlement, Whitney,
Wichita Falls, Winnsboro, Wolfforth, and Wylie, Texas.
. Pursuant to Rule 23( c) ofthe Federal Rules of Civil Procedure, this is to advise you that
there is now pending in the United States District Court for the Western District of Texas, San
Antonio Division (the "Court") a class action brought by the City of San Antonio, Texas (the
"Plaintiff') on behalf of 175 different cities within the State of Texas (the "Class" or the "Texas
Cities"). Your City has been identified as one of these 175 class members.
CLASS ACTION NOTICE - Page I
140808v I
This notice explains:
A. The Nature and History ofthe Lawsuit.
B. The Class Certificatlon Proceedings and Class Certification Order.
C. The Right to be Included in, or Excluded from, the Class.
D. Additional Information.
A. The Nature And History Of The Lawsuit.
This lawsuit was filed by the City of San Antonio on May 8,2006, on behalf of itself and
other allegedly similarly situated cities throughout the State of Texas. The defendants are online
travel companies ("OTCs" or "Defendants") or their affiliates and include the following:
Hotels.com, L.P.; Hotels.com GP, LLC; Hotwire, Inc.; Trip Network, Inc. (d/b/a CheapTickets);
Expedia, Inc;; Internetwork Publishing Corp. (d/b/a Lodging.co:m); Lowestfare.com,
Incorporated; Orbitz; Inc.; Orbitz, LLC; priceline.com, mcorporated; Site59.com, LLC;
Travelocity.com Inc.; Travelocity.com LP; Travelweb LLC; and Travelnow.com, Inc.
Members of the public, either through the internet or by phone, can use the OTCs'
services to make hotel reservations. The Plaintiff alleges that, under the OTCs' merchant model,
the OTCs enter into a contract with the hotel to obtain an inventory of rooms at negotiated
wholesale rates, determine the mark up, set the retail rate that the consumer will pay, and sell the
room to the consumer.
It is undisputed that the OTCs have paid ''tax recovery charges" to the hotels on the
wholesale price of the rooms, but have never paid taxes on the retail price that the consumer pays
when he books a room through the OTCs; As a result, the Plaintiff alleges that a certain amount
of hotel occupancy or "bed" taxes are being lost on every hotel room in each of the Texas Cities
that is booked and paid for through the OTCs. The Plaintiff claims that the OICs should pay
hotel occupancy taxes ou the difference between the retail price of the hotel rooms, which the
occupants pay, and the wholesale price that the OTCs pay the hotels. . The OTCs contend that the
hotel occupancy tax ordinances do not impose a tax on them or the amounts they charge a
customer and retain for their services.
Each City in the Class imposes a "hotel occupancy tax" or "bed tax" on consumers who
stay in a hotel room in that City. Each City has enacted a hotel occupancy tax ordinance
mandating that every person "owning, operating, managing, or controlling" a hotel shall collect
the tax and remit the tax to the City. In this Lawsuit, the Plaintiff has asserted claims on behalf
of itself and each ofthe Texas Cities for violation of their respective hotel tax ordinances. The
Plaintiff) on behalf of the Class, claims that the OICs "control" the hotels and, therefore, (a) the
OICs have a duty to collect bed taxes from the consumers, and (b) regardless of their duty to do
so, the OTCs are, in fact, collecting the bed tax. The Plaintiff also brings, on behalf of itself and
each of the Texas Cities, a common law claim for conversion, alleging that the OTCs must
submit to each Texas City any taxes that they have collected. The Plaintiff seeks to recover
. damages for the amount of taxes that it alleges that it and each of the other Texas Cities have
been underpaid in the past and further seeks an order from the Court that would prohibit the
OICs from allegedly underpaying bed taxes in the future. The Plaintiff also seeks, on behalf of
itself and the Texas Cities, attorneys' fees, costs, penalties, and/or interest.
CLASS ACTION NOTICE - Page 2
140808v I
The OTCs deny that they have any duty to collect or pay bed taxes to the Texas Cities
under the ordinance applicable to each Texas City and, accordingly, deny that they have
underpaid any.bed taxes. More specifically, the OTCs assert that they do not "control" hotels or
hotel operations; therefore, they are not required by law to collect or remit hotel occupancy
taxes. They also assert that only the amounts charged and paid "to hotels" are taxable. The
OTCs also contend that the amounts. charged for their services are not taxable. The OTCs further
claim that they cannot be taxed by cities with which they do not have a substantial nexus because
it would violate their constitutional rights.
R The Class Certification Proceedings And Class Certification Order.
In preparation for the class certification hearing, the parties engaged in extensive
discovery including more then 20 oral depositions as well as the exchange of a substantial
vo lume of documents and electronic discovery. On May 16 and 17, 2007, the Court held an
evidentiary hearing on the Plaintiffs motion for class certification. The Court heard evidence
and legal arguments from all parties. On May 27,2008, the Court entered an Order on Class
Certification and issued a Memorandum and Opinion on Class Certification (the "Class
Certification Order") in which the Court granted the Plaintiffs motion for class certification and
certified the following class.
"T exas cities whose ordinances contain language that requires every person
owning, operating, managing, or controlling any hotel to collect and remit hotel
occupancy taxes and whose ordinances .do not contain administrative prerequisites
to filing a lawsuit for the failure to collect or remit hotel occupancy taxes."
The Plaintiff has identified by name 175 Texas Cities that fit within this class definition,
and Your City is one of these 175 Texas Cities and, therefore, is part of the Class. Pursuant to
the Class Certification Order, the City of San Antonio has been designated to serve as the
representative for the Texas Cities (the "Class Representative"). The Court has further
designated Steven D. Wolens and Gary Cruciani with the law firm of Diamond McCarthy to
serve as lead attorneys for the Texas Cities ("Lead Class Counsel"). In addition, the law firm of
Baron & Budd will serve as co-counsel, and Frank Herrera will serve as local counsel. (All the
above attorneys are collectively referred to as the "Class Counsel").
C. The Right To Be Included In Or Excluded From The Class.
Your City has a right to be included in or excluded from the Class. Either choice will
have consequences, which Your City should understand before making a decision.
1. Your City May Do Nothing And Remain A Member Of The Class. If Your City
wants to remain a member of the Class, it should DO NOTHING at this time. If Your City
~emains in the Class, it will be bound by any judgment entered in this case, whether favorable or
unfavorable to it. By remaining in the Class, Your City will have no obligation to pay any of the
costs or attorneys' fees involved inthis Lawsuit at this time. If the Class prevails in this Lawsuit,
the Court may award attorneys' fees and nontaxable costs that are authorized by law. If
Defendants prevail in this Lawsuit, all costs and attorneys' fees incurred by Plaintiffs and the
Class will bepaid exclusively by Class Counsel.
CLASS ACTION NOTICE - Page 3
140808vl
2. You Mav Remain A Member Of The Class And Be Represented By Your Own
Counsel. If Your City wants to remain a member of the Class, but does not want to be
represented by Class Counsel, Your City may enter an appearance through its own attorney or
request the Court to allow it to intervene (that is, to participate in the case as an individual
plaintiff) through its own attorney. IfYoUT City wants to appear or intervene, your attorney must
file the appropriate documents with the Court on or before August 14, 2008
and must send copies of those documents to each of the counsel listed in paragraph 3
below.
3. Your City Mav Request Exclusion From The Class. If Your City wants to be
excluded from the Class, it must send a written request for exclusion, in the form of a letter
signed by a duly authorized representative of Your City and sent by certified mail, to both of the
following individuals by Amrust 14,2008
Steven D. Wolens
Diamond McCarthy
1201 Elm Street
Suite 3400
Dallas, Texas 75270
Lead Attorney for the Class of Texas Cities
Ricardo Cedillo
Davis, Cedillo & Mendoza, Inc.
McCombs Plaza
Suite 500
755 East Mulberry A venue
San Antonio, Texas 78212
Attorney for Defendants Online Travel Companies
By making the decision to exclude itself from the Class, Your City will not share in any
favorable judgment obtained on behalf of the Class, nor will it be bound by any adverse
judgment entered against the Class.
D. Additional Information.
If Your City desires additional infonnation about this Notice, about the Class
Certification Order, or about this Lawsuit, you should contact Lead Class Counsel as set forth
below.
Steven D. Wolens
Diamond McCarthy
1201 Elm Street
Suite 3400
Dallas, Texas 75270
(214) 389-5347
swolens@diamondmccarthy.com
CLASS ACTION NOTICE - Page 4
140808vl
This Notice does not fully describe the claims and defenses ofthe parties in this litigation
or the status of the Lawsuit. The pleadings and court papers filed in this Lawsuit are available
for inspection and copying at any time during regular office hours in the Office of the Clerk of
the United States District Court for the Western District of Texas, San Antonio Division, which
is located at 655 E. Durango Blvd., San Antonio; Texas 78206-1106. Certain pleadings and
court papers in this lawsuit have been filed under seal and may not be examined or copied
without first obtaining an order from the Court. . In order to inspect the pleadings and court
papers, you must appear in person or through an authorized representative such as an attorney.
PLEASE DO NOT CALL OR WRITE THE COURT OR THE DISTRICT COURT'S OFFICE
FOR. INFORMATION. . (
~ oj
Dated: <...J U VI. -e.. /1-) J.. b
CLASS ACTION NOTICE - Page 5
140808vl
{~~tC
UNITED STATES DISTRICT JUDGE
askins
& askins p.c.
RECEIVED
JUL 1 8 2008
ATIORNEYS and COUNSELORS
Knox W. Askins
Clark T. Askins
C~..\' :;.-;CK.:...AR':'S
Of=~=~'::!
July 16, 2008
Wolens
Diamond M arthy LLP
Renaiss ce Tower
m Street, 34th Floor
s, TX 75270
Re: City of San Antonio, Texas, on Behalf of Itself and All Other
Similarly situated Texas Cities v. Hotels.com, et al.
Case No. SA06CA0381 OG
Dear Mr. Wolens:
In reference to your letter to our office dated June 25, 2008, I
enclose herewith certified copy of ordinance passed by the City of
La Porte City Council on July 14, 2008, expressing the intention of
the city of La Porte to be included in the class of 175 cities, in
the subject litigation.
Our office explained to the City Council that electing to remain in
the class carries no risk to the City of La Porte, based on the
fact that the City of La Porte would not be liable for any costs or
fees, should the litigation be unsuccessful.
Thank you, and should you have any questions, please do not
hesitate to give me a call.
Yours very truly,
~~
Clark T. Askins
Assistant City Attorney
City of La Porte
CTA: sw
Enclo~re
cc: vfi<?n.
City
Mayor & City Council
of La Porte
Mr. Ron Bottoms
City Manager
City of La Porte
702 W. Fairmont Parkway, P.O. Box 1218, La Porte, TX 77572-1218
281.471.1887 phone . 281.471.2047 fax . knoxaskins@comcast.net . ctaskins@swbell.net