Complaint,Petition: CV-2019-493

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                                - * (N-A9-449
ema “Wuong

IN THE DISTRICT COURT OF OKLAHOMA COUNTY

STATE OF OKLAHOMA
SOUTHWESTERN BELL TELEPHONE, )
LP D/B/A AT&T OKLAHOMA, )
)
Plaintiff,
<. IN DISTRICT Cour?
} Case NO. OK) AHOMA COUNTY
THE CITY OF OKLAHOMA CITY )
a municipal corporation, ) FEB 2 8 2019
) ,
Defendant. } 3 TOS aRREN
Fant aes a0
PETITION “ema

COMES NOW the plaintiff and for his/her cause of action against the defendant alleges

and states:

L
That the defendant City of Oklahoma City is a municipal corporation organized and

existing under and by virtue of the laws of the State of Oklahoma.

I.
That on November 25, 2018, the claimant’s buried fiberoptic cable was damaged during a
City crew’s work repairing a broken water main at 301 E Memorial. Claimant alleges damages

in the amount of Twenty-One Thousand Four Hundred Ninety-Nine and 23/100 ($21,499.23).

iH.

That the resulting damages to plaintiff's property was proximately caused by negligence
on the part of the defendant, its agents, officers and employees in one or more of the following
particulars, to wit:

Petition

Page | of 2 pages
Revised 5/14/02a. That the defendant had the duty but failed to exercise due care operating City
equipment; and

b. That the defendant knew or should have known that its failure to exercise due care
under the circumstances would result in damages to the plaintiff's property.

IV.

That as a direct and proximate result of the negligence of the defendant, its employees,
agents and officers, the plaintiff and/or plaintiff's property was damaged in the amount of Twenty-
One Thousand Four Hundred Ninety-Nine and 23/100 ($21,499.23).

WHEREFORE, plaintiff prays judgment against the defendant herein in the total amount

of Twenty-One Thousand Four Hundred Ninety-Nine and 23/100 ($21,499.23) the cost of this

Cn LE. deems just and proper.

SOUTHWESTERN BELL TELEPHONE,
LP D/B/A AT&T OKLAHOMA, Plaintiff

JOID Png St Floor lobla/

Address
Delo WO @310)
City State Zip Code

Petition
Page 2 of 2 pages
Revised 5/14/02