February 15, 1995
TO:
Leslie P. Dixon
District Attorney Van Zandt
I, Udo H. Birnbaum report the following crimes committed by William B. Jones against Udo H. Birnbaum and request your attention to these matters. Both Birnbaum and Jones reside in Van Zandt county and all matters referred to occurred in Van Zandt county.
A report by the Sheriff's Office styled Incident No. 95000270 dated February 8, 1995 is enclosed as documentation of these crimes.
I report the following crimes:
Jones maliciously and negligently destroyed Birnbaum's existing fence at the property line between Jones and Birnbaum for a total distance of about 350 yards. Birnbaum is a rancher who relies on this fence to control his cattle. Jones failed to give any warning to Birnbaum and the fence has been down for more than five (5) months.
Jones trespassed upon the property of Birnbaum by directing the operator of the bulldozer upon the property of Birnbaum, pushing large quantities of brush, debris, and wire fence beyond Jones' property line and up to 25 feet onto the property of Birnbaum. This is willful criminal trespassing.
Jones maliciously and negligently released large quantities of water onto Birnbaum's property by the use of dynamite to blow up a dam existing on Jones's property. Jones failed to give any warning to Birnbaum. Uncontrolled amounts of water containing
sand, driftwood, and debris scoured Birnbaum's land and created ditches, gullies, and uncontrollable erosion. Large quantities of sand, driftwood, and debris remain on Birnbaum's property to this day.I request the District Attorney of Van Zandt to refer these matters
to the County Grand Jury for prosecution.
enc:
Incident Report 95000270
Van Zandt Sheriff's Office
dated 2-8-95
Udo H. Birnbaum
Rt. 1 Box 295
Eustace, Tex. 75124
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