2016 Anthony F. Constant Resume with Construction Cases Summary

ANTHONY F. CONSTANT
CONSTANT LAW FIRM
800 N. SHORELINE BLVD.
ONE SHORELINE PLAZA – SUITE 2700 SOUTH TOWER
CORPUS CHRISTI, TEXAS 78401
PHONE: (361) 698-8000
FAX: (361) 887-8010
EDUCATION:
1971 JD University of Texas School of Law
1971 Admitted to The State Bar of Texas
2008 Admitted to The State Bar of Georgia
Admitted U.S. Court of Appeals, Fifth
Circuit, Court of Appeals, State of Georgia
and the U.S. District Courts, Southern, Eastern
and Western Districts of Texas.
EMPLOYMENT HISTORY:
1971-1973 TEXAS RURAL LEGAL AID
1973-1975 CANALES & GARZA, Associate
1975-1981 LAW OFFICE OF ANTHONY F. CONSTANT
1981-1983 EDWARDS & PERRY (partner)
1983-1986 EDWARDS, MCMAINS
& CONSTANT (partner) 1986–1992
MCMAINS & CONSTANT (partner)
1992-1995 LAW OFFICE OF ANTHONY F. CONSTANT
1995-2004 CONSTANT & VELA (partner)
2004-present CONSTANT LAW FIRM (solo)
PRACTICE AREAS OF CONCENTRATION:
Insurance, Construction and Personal Injury.
1994-2016 Best Lawyers in America
Martindale-Hubbell rating AV
Board Certified - Texas Board of Legal
Specialization
Largest verdict in history of Jim Wells Co. ($80
Million), represented the Plaintiff, January
2001.
Represented Edinburg ISD, Pharr-San Juan
Alamo ISD, San Benito ISD, Rio Grande City
ISD, San Diego ISD and Alice ISD in litigation
over school construction defects. Total recovery
exceeds $61 Million.

Tab
1
2
3
4
5
6
7
Sumary of Settlements involving
Construction Cases
San Benito ISD
Edinburg ISD (2004.02.1 0)
Edinburg ISD (2004.06.28)
Edinburg ISD (2005.12.13)
Pharr San Juan Alamo ISD (2005.08.01)
San Diego ISD (Gignac) 2008.07.16
San Diego ISD (S&P) 2010.09.15
Alice ISD (May 2014)
Corpus Christi ISD v Wisznia**
Tropical Texas Center for MHMR**
TOTAL
** Denotes file is no longer available per
records retention policy.
$ 15,000,000.00
$ 20,370,000.00
$ 2,175,000.00
$ 215,000.00
$ 11,292,883.82
$ 310,000.00
$ 1,000,000.00
$ 154,998.34
$ 1,185,651.86
$ 4,500,000.00
$ 2,172,500.00
$ 2,000,000.00
$ 1,200,000.00
$ 61,576,034.02

~;§TTI;§MBNT STATEMENT
SAN:SBNITO
Consolidated Independent School District
This Settlement Statementshows the calculation of'th.enet payment to be made to the
SANJa:BNITO Conso1idated.llldepcmdent School Pistrlot out ofa !lettleme:ntoflitigation.
by and agai&t Honeywell Internation~ Jnc. described in the ResolutionPassedbythe
Board at the Speoial Called Meeting em the 31111 day ofAugust 2004 that approved and
aeoepted that settlement.
TOTAL RECOVERY
Attomey,st ff;1es
40% ofthe Total Recovery
Utigaticm Exptmses
fJ.m!:
DeferredPayment
NETRBCOVERY
To
San Benito
Consolidated
Independent
School Distclot
$15,000,000.00
<$ 6.000,000.00>
A:Pproved and Accepted this lZ,; day ofOctober 2004by
~SohooiDiotn<tby Its P.resi!ient ofthe Soard ofTrustees
Mr. Oscar De La. )Juento

EDINBURG CONSOLIDATED ISD:
DATE RECOVERY
02-10-2004 $ 20,370,000.00
06-28-2004 $ 2,175,000.00
12-13-2005 $ 215,000.00
Total: $ 22,760,000.00

CAUSE NO. C-1093-02-E
LANDMARK ORGANJZATION, LP. §
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
IN THE DISTRICT COURT
vs.
EDlNBURG CONSOLJDATED
INDEPENDENT SCHOOL DISTRICT
and HIDALGO COUNTY, TEXAS
EDINBURG CONSOUDATED
INDEPENDENT SCHOOL DJSTRJCT
vs.
LANDMARK ORGANJZATION, L.P.,
LANDMARK ORGANlZATJON INC.,
LANDMARK ORGANIZATION
OF TEXAS, lNC., V.A. ARCHITECTURE
and RAY VARGAS 398TH JUDICIAL DISTRlCT
SETTLEMENT STATEMENT
This Settlement Statement shows the calculation of the net payment to be made to the
Edinburg Consolidated Independent School District out of the settlements in this
litigation previously approved by the Board of Trustees which settlements total
$20,370,000. Litigation in this Cause continues against other Defendants and an
additional separate Settlement Statement will be presented with regard to any recovery
made against the remaining Defendants.
TOTAL RECOVERY:
Less: 40% Attorneys' fees:1
Less: Litigation Expenses
NET RECOVERY Edinburg Consolidated Independent
School District &Edinburg Consolidated Independent School
District Public Facilities Corp:
$20,370,000.00
<$8,148,000.00>
<$"148,527.1 0>
$12,073,472.90
Approved and accepted this t OJ:It day of. ~!l..~ 2004 by _Eu~
Gutierrez, Superintendent of Edinburg ClSD~"fi~, ~- T~
The fees will be shared and divided amongst the lawyers who have participated and
continue to participate in the represeniation of the Edinburg CISD and the Edinburg CISD Public
Facilities Corporation in lhe subject litigation. These lawyers are Constant & Vela, Rene
Ramirez, Ricardo Palacios, Ricardo Rodriguez, Juan R. Molina, & Ricardo L Salinas.

LANDMARK ORGANIZATION, I...P. § IN THE DISTRICT COURT
§
~ §
§
EDINBURG CONSOLIDATED §
INDEPENDENT SCHOOL DISTRICT §
§
and § HIDALGO COUNTY, TEXAS
§
eDINBURG CONSOL!OATED §
.INDEPENDENT SCHOOL DISTRlCT § .
§
vs. §
§
LANDMARK ORGANIZATION, L.P., §
LANDMARK ORGANIZATION INC., §
LANDMARK ORGANIZATION . §
OF TEXAS, INC., V.A. ARCHJTECTUR~ §
and RAY VARGAS · § 398TH JUDICIAL DISTRICT
J..H!BQ seTTLEMENT STATEMENT !PARTIAL)
This, Third Settlement Staten.-;;;:tlt (Partial) shows the calculation of the net
payment to be made to the edinburg clonsolidated Independent School District out of a
part of the !;lettlem~antsln thislitlgatlon prbviously approved by the Board of Trustees_
Litigation in this Cause cc.mtinuer:> against other Defendants and an additional
separate Settlement Statement will b' presented with regard to any recovery made
against the remaining Defendants.

Here is the catoulation of the ap~ropliate distribution of this partial sef.11ement
TOTAL RECOVERY THlS DISTRISUTIG.)N:
Less: Attorneys' fees, 40% of this partia11 distribution:1
Less: Litigation Expenses to date not p~eviously reimbursed:
See attached listing
Sub-Total:
Plus: lntewest acorued from 0:3/31/04 thdu 05/31/04
as reported to us by American Bank:
NET RECOVERY to Edinburg Consolid*ted Independent
School District & Edinburg Consolrdated! Independent School
District Public Facillties Corp:
$2,175,000:00
<$738,000.00>2
< $2,254.91>
$1,434,745.09
$8,051.52
$1,442,796.61
Approved and accepted this 2-$1' daY, of Jun~. 2004 by Eugenio Gutierrez,
Supe!"intendent of Edinburg CISD. '
r ·-~
tierrez, Superintend dlnburg Consolidated Independent School District
and as .A r!zed Representativ f Edinburg Consolidated Independent School District
Public Facilities Corp
1 The fees will be shared and divided amongst the lawyers who have partiCipated and
continue to participet~ in the representatloh of the Edinburg CISD and the Edinburg CISD Public
Facilities Corporation in the subject lltibatlon. These lawyers are ConstMt & Vela, Rene
Ral"fflrez, Ricardo Palacios, Ricardo Rodrigpez, Juan R. Molina, & Ri¢G~rdo L. Salinas.
2 This ls Jess than 40% because the lawyer$, took no fee on the $330,000. settlement with Eberle.

EXHIBIT 1
CAUSE NO. C-1093-02~E
LANDMARK ORGANIZATION, L.P. § IN THE DISTRICT COURT
§
V$. §
§
INDEPENDENT SCHOOL DISTRtCT §
§
and § HIDALGO COUNTY~ TEXAS
§.
INDEPENDENT SCHOOL DISTRICT §
§
vs. §
§
LANDMARK ORGANIZATION INC., §
LANDMARK ORGANIZATION §
OF TEXAS, INC., V.A. ARCHITECTURE §
and RAY VARGAS § 398TH JUDJCIAL DiSTRICT
FINAL PARTiAL SETTLEMENT STATEMENT
This Final Partial Settlement Statement shows the calculation of the net payment
to be made to the Edinburg Consolidated Independent School District out of a part of the
settlements in this litigation.
Litigation in this Cause Is now concluded and this is therefore the last and final
Settlement Statement In connection with this litigation.
PAGE 1

EXHIBIT 1
Here is the calculation of the appropriate distribution of thls partial settlement:
TOTAL RECOVERY THIS DISTRIBUTION:
Less: Attorneys' feeS1 40% ofthis partial distribution:1
Less: litigation Expenses to date not previously reimbursed:
See attached listing
SubDTotal:
Plus: Interest accrued from 06/01/04 thru 11/21/05
as reported to us by American Bank and First National Bank
NET RECOVERY to Edinburg Consolidated Independent
School District &Edinburg Consolidated Independent School
District Public Facilities Corp:
Approved and accepted this ~day of December, 2005
by Jose Luis Salinas, Superintendent of Edinburg CISD.
$215,000.00
<$ 86,000.00>
< $ 1,826.32>
$127,173.68
$ 2,889.12
$ 130,062.80
J uis Salinas, Superintendent Edinburg Consolidated Independent School District
and as Authorized Representative of Edinburg Consolidated Independent School District
Public Facilities Corp
The fees will be shared and divided amongst the lawyers who have participated and
continue to participate in the representation of the Edinburg ClSD and the Edinburg CISD Public
Facilities Corporation in the subject litigation. These lawyers are Constant & Vela, Rene
Ramirez., Ricardo Palacios, Ricardo Rodriguez, Juan R. Mollna, & Ricardo L. Safinas.
PAGE2

PSJA ISD:
DATE RECOVERY
08-01-2005 $ 11,292,883.82
09-12-2006 $ 310,000.00
09-25-2006 $ 1,000,000.00
01-03-2007 $ 154,998.34
Total: $ 12,757,882.16

CAUSE NO. C·1038-02-G
LANDMARK OROANIZAT.tON, L.P.. §
Etal, §
§
~ §
§
§
PHARR SAN JUAN ALAMO §
INDEPENDENT SCHOOL DISTRICT, §
Etal
IN THE DISTRICT COUR'...
HIDALGO COUNTY, TEXJt.S
370t11 JUDICIAL D!STRT.CT I
SETTLEMENT STATEMENT {PARTIAL)
This Settlement Statement (Partial) shows the calculation of ]1e net
payment to be made to the Pharr San Juan Alamo Independent School District
as a result of the payment by Landmark of the Arbitration Award and as result
of certain settlements with some of the other Defendants In this cause. T e total
recovery to date from these sources equals $11,292,883.82.
Litlgatlon against the remainlng subcontractors will continue ,,,d an
additional eeparate Settlement Statement will be presented with regard Ito any
recovety made agalnst the remaining subcontractors.
Here ls the calculatlon of the appropriate distribution of this partial
settlement:
RECOVERY TO DATE:
($:4,000,0f:JO.OO)
1 exhibit A shows the source of these funds.
2 The District's attorneys have e,greed to reduce thelr fees owed to them by the District uhder the
contract between the District and its attorneys, The actual fee owed under the co~tract is
$4,517,153.63, which ls 40% ofthe total recovery.

Less: Litigation Expenses to date
Recovery by PSJA after payment of Fees and Costs
Total Interest Earned on all sums to July 18, 2005
$6,620f267.07
$ 19,1D1.q2
NET PARTIAL RECOVERY by PSJA as of July 18, 2005 $6,639,368.Q9
Approved and accepted this _!.st _day of August 2005 by 1
Arturo Guajardo, Superintendent, Pharr San Juan Alamo Independent ScHool
District
~~Arturo GuajardO
Superintendent of Schoors
Pharr San Juan Alamo Independent School District
3 Cost Reimbursement Due to Constant & Vela is $450,215.60. The Di.stdc~ has
previously paid from the settlement ftmds $222,401.25. These expenses are detailTd in
the attached Exhibit B.

CAUSENO. C-1038-02-G
LANDMARK ORGANIZATION, L.P.. §
Etal, §
§
vs. §
§
§
PHARRSAN JUAN ALAMO §
·INDEPENDENT SCHOOL DISTRICft §
Etal
IN THE DISTRlCf COURT
HIDALGO COUNTY,TEXAS
3701&JUDICIAL DISTRICI'
SbTILEMENI STATEMENT {PARTIAL)
This Settlement Statement(Partial) shows the calculation of the net paymentto be
made to the Pharr San Juan Alamo Independent School District as a result of the
settlements wit11 some of the Defendanw in this cau$e. Tbe total recovery to date from
these sources equals $310,000.00.
Litigation against the remaining subcontractors will continue and an additional
separate SettlementStatement will be presented with regard to any recovery made against
the remaining subcontractors.
Here is the calculation of the appropriate distribution ofthis partial settlement:
RECOVERY FROM DEFENDANTS LISTED ON EXHIBIT A: $310,000.001
. -.-..
Less: Attorneys' fees
Less: litigation Expenses to date
($124,000.00)
($17.361.S4Y~
$168,fi38.46
Approved and accepted this 12th day of§e;e!ember •2006 by
Arturo Guajardo, Superintendent,Pharr San Juan Alamo Independent Scltool District
~~Arturo Guajardo
SuperintendentofSchools
1 Exhibit A.shows the source ofthese funds.
2 CostReimbursement Due to Constant & Vela is $17,361.54. These expenses are
detailed in the attached ExhibitB.
EXHIBIT 1

Etal, §
§
vs. §
§
§
INDEPENDENT SCHOOL DISTRICf, §
Eta!
IN THE DISTRICf COURT
HIDALGO COUNTY1 TEXAS
370111 JUDICIAL DISTRicr
S.EIJLEMENT STATEMENT (PARTIA.L}
This SettlementStatement (Partial) shows the calculation of the net payment to be
settlement with N Cardenas Masonry. Inc. one ofthe Defendants in this cause. The total
recovery to date from this source equals $1,000,000.00.
separate Settlement Statement will be presented with regard to any recovery made against
Here is the calculation ofthe appropriate distribution of this partial settlement:
RECOVERY FROM DEFENDANTS LISTED ABOVE:
~ess:Jtoarneys'fees
Recovery by PSJA after payment of Fees
$1.000,000.00
($400.000.00)
$600,000.00
Approved and accepted this 25th day of September 2006 by
Arturo Guajardo, Superintendent, Pharr San Juan Alamo Independent School District
~~Arturo Guajardo
Superintendent of Schools
Pharr San Jmm Alamo IndependentSchool District •,,__
EXHIBIT 1

CAUSE NO. C-1038~02..0
Eta!, §
§
vs. §
§
§
INDEPENDENT SCHOOL DISTRICf. §
Etal
IN THE DlSTRICf COURT
HIDALGO COUNTYI TEXAS
370~11 JUDICIAL DISTRlCf
SEITLEMENT STATEMENT' CfARTlAL}
This Settlement Statement (Partial) shows the calculation of the net payment to be
settlements with some of the Defendants in this cause. The total recovery to date from
these sources equals $154,998.34.
separate SettlementStatement will be presented with regard to any recovery made against
Here is the calculation of the appropriate distribution of this partial settlement:
RECOVERY FROM DEFENDANTS USTED ON EXHIBIT A: $154,998.341
Less: Attorneys' fees
Less: Litigation Expenses to date
($61,999.34)
($4,690.49i~
$88;108.51
-~rc/ -rApprovedand accepted this ~,_,~ day of. Cit:?. n.1t(d_~~ ~ 2007 by
Arturo Guajardo, Superintendent, Pharr San J11an Alamo ndependent School District
~~Arturo. Guajardo
Superintendent of Schools
1 Exhibit A shows the source of these funds.
2 Cost Reimbursement Due to Constant & Vela is $4,690.49. These expenses are detailed inthe
attached Exhibit B.

SAN DIEGO ISD:
DATE RECOVERY
07-16-2008 (Gignac) $ 1,185,651.86
09-15-2010 (S&P) $ 4,500,000.00
Total: $ 5,685,651.86

CAUSE NO. DC-07-287
SAN DIEGO INDEPENDENT
INDEPENDENT SCHOOL DISTRICT
vs.
RAYMOND GIGNAC,
GIGNAC and ASSOCIATES,
GIGNAC & ASSOCIATES, LLP a.nd
SHW GROUP, INC.
§
§
§
§
§
§
§
§
§
IN THE 229th JUDICIAL
DISTRICT COURT OF
DUVAL COUNTY, TEXAS
SETTLEMENT STATEMENT [PARTIAl"]
This Settlement Statement !PARTIAL} shows the calculation of the net payment to be
made t:o the San Diego Independent School District, after the deduction for payment of
attorneys' fees and reimbursement of litigation expenses, as a result of the settlement with
Raymond Gignac, Gignac and Associates, Gignac & Associates, LLP (hereinafter "Gignac").
The total recovery from Gignac is $1,185,651.86.
Litigation against Satterfield and Pontikes Construction, Inc. is still pending in a different
cause number.
Here is the calculation of the appropriate distribution of this partial settlement;
RECOVERY FROM GIGNAC:
Less: Attorneys' fees 1:
Less: Litigation Expenses Not Previously
Reimbursecfl:
NET RECOVERY by SDISD
$ 1,185,651.86
$ 474,260.72
$ 102,346.48
$ 609,044.66
Approved and accepted this /{.g~ day of July, 2008 by Luis A. Pizzini, Superintendent,
San Diego Independent School District
Y!.. u~-~ini
San Diego ISD Superintendent
1 The fee will be shared bclwccn the attorneys representing the District in this matter in accord with the agreements
previously made.
2 Cost Reimbursement due to Anthony f. Constant is $!02,346.60 is detalled in the attached "Exhibit A."

CAUSE NO. DC-06-74
SAN DIEGO INDEPENDENT
SCHOOL DISTRICT
§
§
§
§
§
§
§
§
IN 229th JUDICIAL
vs. DISTRICT COURT OF
SATTERFIELD AND PONTIKES
CONSTRUCTION, INC. DUVAL COUNTY, TEXAS
SETTLEMENT STATEMF.NT
San Diego Independent School District, after the deduction for payment of attorneys' fees and
reimbursement of Htigation expenses, as a result of settlement with Satterfield and Pontikes
Construction, Inc. and its Subcontractors (hereinafter "S&P").
The total recovery from S&P and its subcontractors is $4,500,000.00.
Here is the calculation of the appropriate distribution ofthis settlement:
RECOVERY FROM S&P AND ITS SUBCONTRACTORS: $
Less: Attorneys~ fees 1 $
Less: Litigation Expenses2 $
NET RECOVERY by SDISD $
4,500,000.00
(1 ,800,000.00)
(95,483,48)
2,604,516.52
Approved and accepted this 15th day of September, 2010 by Dr. Ignacio Salinas,
Superintendent, San Diego Independent School Di.strict.
. Ignacio Salinas
San Diego ISD Superintendent
1 The fee wilt be shared between the attomeys representing the District in this mauer in accord with the
agreements previously made.
2 Cost Reimbursement due to Anthony F. Constant is $95,483.48 is detailed in the al!ached "Exhibit A."

ALICE ISD:
DATE RECOVERY
05-12-2014 (Womack) $ 930,000.00
05-12-2014 (Masonry) $ 160,000.00
05-19-2014 (Coym) $ 897,500.00
05-19-2014 (Tellez/JQ) $ 185,000.00
Total: $ 2,172,500.00

WOMACK
SETTLEMENT STATEMENT
Alice Independent School District, after the deduction for payment of attorneys' fees and
reimbursement of litigation expenses, as a result of the settlement with LaMarr Womack, LaMarr
Womack doing business as LaMarr Womack and Associates Architects, LaMarr Womack and
Associates, L.P., LaMarr Womack and Associates Architects, Inc. (hereinafter "Womack
Defendants") of all claims brought against the Womack Defendants in Cause No. 12~05-52283-
CV and in Cause No. 13-08-52552-CV in the District Court of Jim Wells County, Texas.
The total recovery from Womack Defendants is $931 ,0701•
Here is the calculation of the appropriate distribution ofthis settlement:
RECOVERY FROM WOMACK DEFENDANTS:
Less: Attorneys' fees 2
$ 930,000.00
$ (372,000.00)
Less: Litigation Expenses re AISD v Womack:/Moorhouse3 $ (160,625.73)
Less: Litigation Expenses re AISD v Tellez4 $ (68,101.16)
NET RECOVERY by AISD $ 329,273.11
trHJI
Approved and accepted this~ day of~~;-~' 2014 by Dr. Grace Everett
Superintendent, Alice Independent School District.
Dr. Grace Everett
AL.ICE ISD SUPER1NTENDENT
1 The precise number is $931,070 less any additional defense costs and expenses incurred by Defendants after
April II, 2014. Jfpayment of more than $930,000. is received, that additional sum will be paid to the District.
2 The fee will be shared between the attorneys representing the District in this matter in accord with the agreements
previously made.
3 Cost Reimbursement is detailed in the attached "Exhibit A."
4 Cost Reimbursement is detailed in the attached "Exhibit B."

COYM
SJ'4:TJ=:J~M.ENTST~l'E.M..t~NT
reimbursement of litigation expenses, as a result of the settlement with Pedro Anaya, Patrick
Coyrn, Coym Rehmet & Gutierrez Engineering, L.P. and Coym Rehmet & Gutierrez, Inc.
!hereinafter collectively "the Coym Defendants"! of all claims brought against the Coym
Defendants in Cause No. 13-05-52283-CV and in Cause No. lJ-08-52552-CV in the District
Court of Jim Wells County, Texas.
The total recovery from Coym Defendants is $897,500.00.
Here is the calculation of the appropriate distribution of this settlement
RECOVERY FROM COYM DEFENDANTS:
Less: Litigation Expenses re AISD v Womack/Moorhouse
Less: Litigation Expenses re AISD v Tellez
NET RECOVERY by AISD
$
$
$
$
$
897,500.00
(359,000.00)
(-0-)
(-0-)
538,500.00
Approved and accepted this day of May, 2014 by Dr. Grace Everett
Superintendent, Alice Independent School District
Dr. Grace Everett
ALICE lSD SUPERINTENDENT
1 The fcc will be shared bctwt;cn the attorneys representing the District in this matter in accord with the agreements
previously made.

CAUSE NO. 13-05-52283-CV
ALICE INDEPENDENT SCHOOL DISTRICT § IN THE 79TH JUDICIAL DISTRICT
PLAINTIFF §
§
V. §
§
LAMARR WOMACK, LAMARR WOMACK § OF JIM WELLS COUNTY, TEXAS
DOING BUSINESS AS LAMARR WOMACK §
AND ASSOCIATES ARCHITECTS, §
LAMARR WOMACK AND ASSOCIATES, L.P., §
LAMARR WOMACK AND ASSOCIATES §
ARCHITECTS, INC., PATRICK COYM, §
COYM REHMET & GUTIERREZ ENGINEERING §
L.P.. COYM REHMEr & GUTIERREZ, INC. §
f/k/a COYM REHMEr & GUTIERREZ §
ENGINEERING, INC., MOORHOUSE §
CONSTRUCTION. MOORHOUSE §
CONSTRUCriON COMPANY, INC., §
THE MOORHOUSE PARTNERSHIP, §
TOM'S ASPHALT PAVING & SEPTIC TANK §
SERVICE, INC.,J.N. SANFORD & SON, §
DONNELLY & SONS, INC., §
GARRETT CONSTRUCTION CO., §
FINNEGAN CONSTRUCTION, INC., §
A.Z. REBAR CONSTRUCTION, INC., §
S.S. SMITH & SONS MASONRY. INC., §
PORT ENTERPRISES, LTD., §
PORT ENTERPRISES ROOFING, INC., §
FLOOR COVERING SPECIALISTS OF SOUTH §
TEXAS, LTD., and §
FLOOR COVERING SPECIALISTS, INC. §
DEFENDANTS § 79t" JUDICIAL DISTRICT
SETILEMENISTAIEMJ!;Nt
for
A. Z. Rebar Construction, Inc. and Finnegan Construction, Inc. and
S. S. Smith & Sons Masonry, Inc.
Alice Independent Schoo.! District, after the deduction for payment of attorneys' fees and
reimbursement of litigation expenses, as a result of the settlement with A. Z. Rebar Construction,
Inc., Finnegan Construction, Inc. and S. S. Smith & Sons Masonry, Inc. (hereinafter "Masonry
EXHIBIT

Defendants").
The total recovery from Masonry Defendants is $160,000.00.
Here is the calculation of the appropriate distribution of this settlement:
RECOVERY FROM MASONRY DEFENDANTS:
Less; Litigation Expenses
$ 160,000.00
$ (64,000.00)
$ (0)
$96,000.
Approved and accepted this 121" day of May 2014 by Dr. Grace Everett Superintendent,
San Diego Independent School District
Dr. Grace Everett
Alice ISD Superintendent
1 The fee will be shared between the attorneys representing the Di.stricl in this matter in accord with the
agreemtmts previously made.

TELLEZ JASTER-QUINTANILLA
S1~IILE_MENI_£'L~]]~MENI
reimbursement of litigation expenses, as a result of the settlement with Agustin Tellez, Jr. and
Jaster~Quintanilla San Antonio, LLP [hereinafter collectively the "Tellez JQ Defendants"! of all
claims brought against the Tellez JQ Defendants in Cause No. 13-08-52552-CV in the District
Court of Jim Wells County, Texas.
The total recovery from the Tellez JQ Defendants is $185,000.00.
Here is the calculation of the appropriate distribution of this settlement:
RECOVERY FROM Tellez JQ Defendants:
Less: Litigation Expenses re AISD v Tellez
$ 185,000.00
$ (74,000.00)
$ (-0-)
$ 111,000.00
Approved and accepted this _fj_ day of May, 2014 by Dr. Grace Everett
Superintendent, Alice Independent School District.
Dr. Grace Everett
ALICE lSD SUPERINTENDENT
1 The fee will be shared between the attorneys representing the District in this matter in accord with the agreements
previously made.
EXHIBIT"3"

CAUSE N0.02-03995-00-0-H
CORPUS CHRISTI
INDEPENDENT SCHOOL
DISTRICT
Plaintiff,
v.
WISZNIA & ASSOCIATES;
EWING CONSTRUCTION CO.,
INC.; GPM ENGINEERING;
THURMAN-FONDREN GLASS
COMPANY; HAAS-ANDERSON
CONSTRUCTION LTD.; KMR
INTERIORS, INC.;
WEATHERTROL, INC.;
Defendants
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
IN THE DISTRICT COURT
OF NUECES COUNTY, TEXAS
347th JUDICIAL DISTRICT
PLAINTIFF'S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
1. This matter should proceed under Discovery Control Plan 3 pursuant to
TEx.R.Crv.P. 190.4 and Plaintiff asks this Court to enter a Level 3 Discovery Control
Plan.
2. The Defendant Wisznia & Associates is a corporation qualified to business in the
State of Texas and may be served with citation by serving Andrew J. Lehrman at 711 N.
Carancahua Street; Suite 1200; Corpus Christi, Texas 78411; by certified mail, return
receipt requested.
3. The Defendant Ewing Construction Company is a corporation qualified to do
business in the State of Texas and may be served with citation by serving its registered
agent William B. Ewing at 905 Cantwell Lane; Corpus Christi, Texas 87408 by certified
mail, return receipt requested.

4.
5.
6.
7.
8.
9.
The Defendant GPM Engineering is qualified to do business in the State of Texas
and may be served with citation by serving its registered agent James Grigsby at 713
Bradshaw; Corpus Christi, Texas 78412 by certified mail, return receipt requested.
The Defendant Thurman-Fondren Glass Company is a corporation qualified to do
agent Herbert R. Fondren at 4233 S.P.I.D.; Corpus Christi, Texas 78400 by certified mail,
return receipt requested.
The Defendant Haas-Anderson Construction Ltd. is a corporation qualified to do
agent Darryl 0. Haas at 1401 Holly Road; Corpus Christi, Texas 78415 by certified mail,
return receipt requested.
The Defendant KMR Interiors, Inc., is a corporation qualified to do business in
the State of Texas and may be served with citation by serving its registered agent
Kenneth M. Rives at 3637 Castle River Drive; Corpus Christi, Texas 78411 by certified
mail, return receipt requested.
The Defendant Weathertrol, Inc., is a corporation qualified to do business in the
State of Texas and may be served with citation by serving its registered agent Lee
Mahoney at 4411 Gollihar; Corpus Christi, Texas 78411 by certified mail, return receipt
requested.
Venue is mandatory in Nueces County, Texas pursuant to CPRC §15.011 because
this action is for recovery of damages to real property. Venue is also proper in Nueces
Cmmty under the general venue rule CPRC §15.002 because all or a substantial part of
the events or omissions giving rise to the claims against the Defendants occurred in

10.
11.
Nueces County. Additionally, one or more defendants has its principal office in Nueces
County, Texas. Also, one or more defendants has contracted with Plaintiff in writing to
perform an obligation in Nueces County and this suit is instituted on or by reason of said
obligation making venue in Nueces County proper pursuant to CPRC §15.035.
Defendants each agreed to provide certain goods and services to the Plaintiff
involving the construction of the Ella Barnes Elementary School which was completed in
1992 and is owned and operated by Plaintiff Corpus Christi Independent School District,
but failed to use ordinary care in the construction of the school as required by law and by
their agreements with the Plaintiff and as a direct result of their conduct, breach of
warranty and breach of contract, the school has suffered physical damage to the school
property and the Plaintiff Corpus Christi Independent School District has suffered
substantial financial loss and loss of use. Such damages are within the jurisdictional
limits ofthis Court.
Plaintiff prays that upon trial the Plaintiff have judgment against the Defendants
jointly and severally for actual damages including direct, incidental and consequential
damages, for costs of court, for pre-judgment interest, and for all the other relief to which
it is justly entitled.
PLAINTIFF DEMANDS A JURY TRIAL.
Respectfully submitted,
CONSTANT & VELA
1570 Frost Bank Plaza
Corpus Christi, Texas 78470
Telephone: (361) 698-8000
Telecopier: (361) 887-8010

ANTHONY F. CONSTANT
ATTORNEY IN CHARGE
State Bar No. 04711000
FILEMON B. VELA, JR.
Telephone: (361) 698-8000
Telecopier: (361) 887-8010
HUSEMAN & PLETCHER
VAN HUSEMAN
State Bar No. - - - -
ANTHONY E. PLETCHER
State Bar No. - - - -
600 Leopard Street, Suite 2100
Telephone: (361) 883-3563
Telecopier: (361) 883-0210
PRUETT MOORE, III
PRUETT MOORE, III; ATTORNEY AT LAW
Telephone: (361) 698-8000
Telecopier: (361) 887-8010
RENE RAMIREZ
LAW OFFICE OF RENE RAMIREZ
1906 Tesoro Blvd
Pharr, Texas 78577
Telephone: (956) 783-7880
Telecopier: (956) 783-7884
4

CAUSE NO. C-231-02-G
TROPICAL TEXAS CENTER FOR § IN THE DISTRICT COURT
MENTAL HEALTH AND §
MENTAL RETARDATION §
Plaintiff, §
§
v. § OF HIDALGO COUNTY, TEXAS
§
JAMES M. SKAINES, JR. §
CORNERSTONE §
ARCHITECTURAL SERVICE; §
SALAZAR CONSTRUCTION, §
INC., and TRI CITY STEEL & §
FABRICATING, INC.. §
Defendants § 370TH JUDICIAL DISTRICT
PLAINTIFF'S FIRST AMENDED ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
1. This matter should proceed under Discovery Control Plan 3 pursuant to
Tex.R.Civ.P. 190.4 and Plaintiff asks this Court to enter a Level3 Discovery Control Plan.
2. Defendant James M. Skaines, Jr. is an individual, who resides in Colorado,
whose principal address is 7028 South Kline Way; Littleton, Colorado 80127. Defendant
Skaines conducts business in the State of Texas without maintaining a regular place of business
in Texas, is without a registered agent for service in this State, and may be served with process
by serving the Texas Secretary of State pursuant to Sec. 17.044 of the Texas Civil Practices &
Remedies Code. This proceeding arises out of the acts and business done by said Defendant in
and affecting this State.
3. Defendant Cornerstone Architectural Services, Inc is a corporation duly
incorporated in the State ofTexas and may be served with citation by serving its registered
agent C. Michael Lawler at 864 Dent Street; Garland, Texas 75040 by certified mail, return
receipt requested.
(,?

4. Defendant Salazar Construction, Inc. is a corporation duly incorporated in the
State of Texas and may be served with citation by serving its registered agent Ismael C. Salazar
at 2434 Sacky Drive; Corpus Christi, Texas 78467-7049 by certified mail, return receipt
requested.
5. Defendant Ismael C. Salazar is a resident ofthe State of Texas and may be
served with citation at his address located at 146 River Trail; Robstown, Texas 78380 by
certified mail, return receipt requested.
6. Defendant Tri City Steel & Fabricating , Inc. is a corporation qualified to do
business in the State of Texas and may be served with citation by serving its registered agent
James Luther at P.O. Box 733, N. Sugar Road; Pharr, Texas 78577
7. Venue is mandatory in Hidalgo County, Texas pursuant to CPRC
§15.011 because this action is for recovery of damages to real property. Venue is also proper
in Hidalgo County under the general venue rule CPRC §15.002 because all or a substantial part
ofthe events or omissions giving rise to the claims against the Defendants occurred in Hidalgo
County. Also, one or more defendants has contracted with Plaintiffin writing to perform an
obligation in Hidalgo County and this suit is instituted on or by reason of said obligation
making venue in Hidalgo County proper pursuant to CPRC §15.035.
8. Defendants each agreed to provide certain goods and services to the Plaintiff
involving the construction of the Tropical Texas Center for Mental Health and Mental
Retardation but failed to use ordinary care in the construction of the Center as required by law
and by their agreements with the Plaintiff and as a direct result oftheir conduct, breach of
warranty and breach of contract, the Center has suffered physical damage to the Center's
property and the Plaintiffhas suffered substantial financial loss and loss ofuse. Such damages
are within the jurisdictional limits of this Court.
9. Plaintiff prays that upon trial the Plaintiffhave judgement against the
Defendants jointly and severally for all its damages, for costs of court, for pre-judgement
interest, and for all the other relief to which it is justly entitled.
PLAINTIFF DEMANDS A JURY TRIAL.
Respectfully submitted,
CONSTANT & VELA

Telephone: (361) 698-8000
Telecopier: (361) 887-8010
ANTHONY F. CONSTANT
ATTORNEY IN CHARGE
FILEMON B. VELA, JR.
Telephone: (361) 698-8000
Telecopier: (3610 887-8010
PRUETT MOORE, III
PRUETT MOORE, III ATTORNEY AT LAW
Telephone: (361) 698-8000
Telecopier: (3610 887-8010
RENE RAMIREZ
LAW OFFICE OF RENE RAMIREZ
1906 Tesoro Blvd
Pharr, Texas 78577
Telephone: (956) 783-7880
Telecopier: (956) 783-7884

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