An Interesting Look at Mechanic’s Lien Priority and Necessary Parties

Businessman holding file

The facts are key when discussing a mechanic’s lien and its enforcement.

May 13, 2019
Christopher G. Hill - Construction Law Musings

As regular readers of Construction Law Musings are well aware, I like to discuss mechanic’s liens. Whether it is their picky nature, the way court’s treat them or the soon to take effect changes in the form, mechanic’s liens are a topic near and dear to my heart as a construction attorney.

This past month the Fairfax Circuit Court took on the intersection of mechanic’s lien priority under Virginia Code section 43-21 (the lien priority statute) and what constitute necessary parties that must be named in any enforcement suit. In Marines Plumbing, LLC v. Durbin, et al., the Court discussed an all too typical scenario. Marines Plumbing performed repair work on the defendants’ property and the defendants did not pay for the work. Marines Plumbing recorded a memorandum of lien and subsequently sued to enforce that lien. In filing its suit, Marines Plumbing failed to name the trustees and lender on a deed of trust securing the loan on the property. Needless to say, the Defendants moved to dismiss the action for failure to name necessary parties (lender and trustees).

Mr. Hill may be contacted at

Construction Law and Ethics Seminar

May 13, 2019
Beverley BevenFlorez - CDJ Staff

This one-day, in-person seminar will cover a variety of topics, including “Facilitating the Project with Effective Construction Contracting,” “Protecting the Project with Bonds and Insurance,” “Making Changes and Resolving Disputes during the Construction Process,” and “Handling Ethical Issues in Construction.” Attendees of the seminar will learn to do the following:

  • Understand project delivery systems and key contract terms.
  • Consider protecting the project with bonds and insurance.
  • Make changes and resolve disputes during the construction process.
  • Avoid ethical issues during the bidding process.
  • Incorporate environmental ethics and sustainability into construction projects.

June 12th, 2019
Holiday Inn Airport SE-Mall Area
2700 Pilot Knob Road
Eagan, MN 55121

Revised Federal Rule Regarding Class-Wide Settlements

Business man holding scale of justice

The amendments to Rule 23 provide long-overdue clarity concerning certification, notice and objections surrounding proposed settlement classes.

May 13, 2019
Edward M. Koch & Michael Jervis - White and Williams LLP

The United States Supreme Court recently approved and adopted amendments to Federal Rule of Civil Procedure 23 concerning class action practice as proposed by the Advisory Committee on Civil Rules. The amended rule went into effect on December 1, 2018. The amendments do not affect the core of the rule – the criteria for obtaining class certification. Instead, the changes are more subtle adjustments that update and modernize procedures and processes for notification to class members and obtaining approval of class settlements. Nonetheless, although the amendments are not breathtaking, there are important changes.

The first set of amendments apply to Rule 23(e), governing the process of settlement of a class action. First, the amendment makes explicit that the subsection applies not just to already certified classes, but also “a class proposed to be certified for purposes of settlement.” The changes also add some discretion of the court concerning when notice of a proposed settlement and settlement class should be provided. As part of the settlement approval process, the parties now are expressly required to give the court “information sufficient to enable it to determine whether to give notice of the proposal to the class.” The giving of notice is justified only if that information is sufficient to allow the court to determine it is likely to approve the proposed settlement and certify the class. Once notice is approved, the new rule recognizes modern developments by allowing that notice may be by “United States mail, electronic means, or other appropriate means.” The rule thus recognizes that in many cases traditional mail notice may still be best; in others e-mail notification might be the best way to reach class members.

Reprinted courtesy of Edward M. Koch, White and Williams LLP and Michael Jervis, White and Williams LLP
Mr. Koch may be contacted at
Mr. Jervis may be contacted at

Code Changes Pave Way for CLT in Tall Buildings and Spark Flammability Debate

Candles in a row with black background

The new codes will be included in the 2021 edition of the IBC, pending the announcement of official results in the first quarter of 2019.

May 13, 2019
Sam Barnes - Construction Executive

Although nothing new, the debate over which is better as a building material—wood or concrete—intensified in December following the preliminary approval of new codes for cross-laminated timber and mass timber in tall structures.

The discussion among industry professionals has been less about CLT’s structural capabilities and more about its perceived flammability, with either side offering decidedly different perspectives. Comparatively new to the United States, CLT and mass timber products are constructed of several layers of pressed lumber board stacked in alternating directions.

In December, the International Code Council released the unofficial voting results on several code change proposals, including passage of the entire package of 14 tall mass timber codes. The proposals were presented by the ICC’s Ad Hoc Committee on Tall Wood Buildings, comprised mostly of engineers, architects, building and fire code officials, fire service, materials and testing lab representatives.

Reprinted courtesy of Sam Barnes, Construction Executive, a publication of Associated Builders and Contractors. All rights reserved.

60-Day Clock For Statutory Bad Faith “Cure Period” Starts When Civil Remedy Notice Electronically Filed

May 6, 2019
David Adelstein - Florida Construction Legal Updates

The Second District Court of Appeal in Harper v. Geico General Insurance Company, 44 Fla.L.Weekly D618c (Fla. 2d DCA 2019) explained that the 60-day clock for a statutory bad faith cure period STARTS when the civil remedy notice is electronically filed with Florida’s Department of Financial Services:

Subsection 624.155(3)(d) plainly states that no action shall lie if the damages are paid or corrective action is taken within sixty days after the insured files the CRN [Civil Remedy Notice]. Under current procedures, an insured files a CRN with the Department electronically. See Fla. Admin. Code R. 69J-123.002(1). And while the Department also requires the insured to print a copy of the completed CRN from the Department’s website and send it to the insurer, the Department nevertheless considers the form to be “filed” when the insured clicks the “submit” button at the end of the electronic form.[...]

Mr. Adelstein may be contacted at

What is a Subordination Agreement?

Blue question mark

The law surrounding subordination agreements is complicated and there are many intricacies that only an experienced attorney will be able to analyze.

May 6, 2019
Bremer Whyte Brown & O'Meara LLP

Put simply, a subordination agreement is a legal agreement which establishes one debt as ranking behind another debt in the priority for collecting repayment from a debtor. It is an arrangement that alters the lien position. Without a subordination clause, loans take chronological priority which means that a deed of trust recorded first will be considered senior to all deeds of trusts recorded after. As such, the oldest loan becomes the primary loan, with first call on any proceeds from a sale of a property. However, a subordination agreement acknowledges that one party’s claim or interest is inferior to that of another party in the event that the borrowing entity liquidates its assets. Further, shareholders are subordinate to all creditors.

The junior debt is referred to as a “subordinated debt”, and the debt which has a higher claim to any assets is the senior debt. Often, the borrower does not have enough funds to pay all debts, and lower priority debts may receive little or no repayment. For example, if a business has $400,000 in senior debt, $100,000 in subordinated debt, and a total asset value of $420,000, upon liquidation of the company, only the senior debtholder will be paid in full. The remaining $20,000 will be distributed among the subordinated debtholders. Subordinated debts are, therefore, riskier and lenders will require a higher interest rate as compensation.

Construction Reaches Half-Way Point on San Diego's $2.1 Billion Mid-Coast Trolley

Two construction workers looking at plans

The $2.1-billion Mid-Coast Trolley is the largest public transit project in San Diego History.

May 6, 2019
Greg Aragon - Engineering News-Record

Project officials for the $2.1-billion Mid-Coast Trolley in San Diego recently celebrated the halfway point of construction. The event was held at the construction staging yard near the Voigt Drive Trolley station, where workers gather for their morning briefings.

ENR may be contacted at

ABC Legislative Week, Includes Legal Conference

May 6, 2019
Beverley BevenFlorez - CDJ Staff

The American Builders and Contractors organization presents a week at Washington, D.C. with a different event presented each day. ABC Legislative Week opens with a Diversity Inclusion Summit on June 24th, followed the next day by a Young Professionals Symposium. Don’t miss the Free Enterprise Alliance Reception on June 25th, or Legislative Day on June 26th. ABC’s Legal Conference (on June 27th) covers the latest developments and insights on employment and labor law and open competition in the construction industry.

June 23rd-27th, 2019
Hyatt Regency Washington on Capitol Hill
400 New Jersey Ave N.W.
Washington, D.C. 20001

Attorney’s Fees Entitlement And Application Under Subcontract Default Provision

Words over clouds bills finance receipt past final legal

What is the enforceability of the provision and how it is applied in the context of a dispute between a contractor and its subcontractor where both parties have asserted claims against the other?

May 6, 2019
David Adelstein - Florida Construction Legal Updates

Many subcontracts contain a provision in the default section that reads something to the effect:

“Upon any default, Subcontractor shall pay to Contractor its attorney’s fees and court costs incurred in enforcing this Subcontract or seeking any remedies hereunder.”

Oftentimes, a party may wonder as to the enforceability of the provision and how it is applied in the context of a dispute between a contractor and its subcontractor where both parties have asserted claims against the other.

In an opinion out of the Middle District of Georgia, U.S. f/u/b/o Cleveland Construction, Inc. v. Stellar Group, Inc., 2019 WL 338887 (M.D.Ga. 2019), a subcontractor and prime contractor on a federal construction project each asserted claims against the other in the approximate amount of $4 Million, meaning there was a potential $8 Million swing in the dispute.

The subcontract contained a provision entitling the contractor to recover attorney’s fees incurred in enforcing the subcontract or seeking remedies under the subcontract upon any default, identical to the provision above.

Mr. Adelstein may be contacted at

Alaska District Court Sets Aside Rulings Under New Administration’s EO 13795

Lawyer talking to judge illustration

The U.S. District Court for the District of Alaska issued two separate rulings that reversed and set aside energy and environmental decisions made by the current administration.

May 6, 2019
Anthony B. Cavender - Gravel2Gavel

On March 29, the U.S. District Court for the District of Alaska issued two separate rulings that reversed and set aside energy and environmental decisions made by the current administration, which had revoked decisions made in these same matters by the prior administration. The cases are League of Conservation Voters, et al., v. Trump (concerning the development of oil and gas leases on the Outer Continental Shelf (OCS)) and Friends of Alaska National Wildlife Refuges, et al., v. Bernhardt, Acting Secretary of the U.S. Department of the Interior (which concerns a Land Exchange that would facilitate the construction of a road between two remote Alaska communities when that road would traverse parts of a designated national wilderness).

In the League of Conservation Voters matter, the District Court held that the President’s Executive Order 13795 (released on April 28, 2017), which purported to revoke President Obama’s decisions to withdraw certain OCS tracts from oil and gas exploration and development, was unlawful because it was not authorized by Section 12(a) of the Outer Continental Shelf Lands Act (OCSLA). In 2015 and 2016, President Obama issued Presidential Memorandums and an Executive Order withdrawing these particular tracts.

Mr. Cavender may be contacted at

Court Slams the Privette Door on Independent Contractor’s Bodily Injury Claim

Zoom of doornob on door

This decision continues a recent trend that has been percolating in the appellate courts of California.

May 6, 2019
Brett G. Moore, Michael C. Parme, Lindsey N. Ursua & Lawrence S. Zucker II - Haight Brown & Bonesteel LLP

In Johnson v. The Raytheon Company, Inc., Case No. B281411 (2019) WL 1090217, plaintiff Laurence Johnson (Johnson) was a maintenance engineer employed by an independent contractor that provided control room staff to defendant Raytheon Company, Inc. (“Raytheon”). Johnson was monitoring the computers in the control room when he received low water level alarms pertaining to the water cooling towers. Johnson went to the cooling tower wall in order to look over the wall and verify the water level. Johnson saw the upper half of an extension ladder leaning against the cooling tower’s wall. The ladder had a warning sign which said, “CAUTION” and “THIS LADDER SECTION IS NOT DESIGNED FOR SEPARATE USE.” Despite these warnings, Johnson used the ladder. As he was climbing the ladder it slid out causing him to fall and suffer injuries.

Johnson sued Raytheon, the hirer of the independent contractor, arguing the ladder, among other things, was unsafe and lead to Johnson’s injuries. Johnson believed that Raytheon’s course of conduct of leaving a platform ladder (as opposed to the extension ladder) at the wall constituted an implied agreement to always have one present, on which the independent contractor’s employees relied. Johnson further argued that Raytheon was negligent in providing a dangerous extension ladder, as opposed to a platform ladder, at the wall on the night of the accident.

Reprinted courtesy of Haight Brown & Bonesteel LLP attorneys Brett G. Moore, Michael C. Parme, Lindsey N. Ursua and Lawrence S. Zucker II
Mr. Moore may be contacted at
Mr. Parme may be contacted at
Ms. Lindsey may be contacted at
Mr. Lawrence may be contacted at

Be Careful in Contracting and Business

Three businessmen sharing ideas, looking pensive

Make sure that the contracts that you sign are such that you know your rights, with precision at the outset.

May 6, 2019
Christopher G. Hill - Construction Law Musings

After an hour long phone conference with a client, I have had several thoughts, only a few of which I can share here (grin). The first is that my friends and clients in the construction industry are hurting, but need to work with an attorney to assure that the pain is lessened. The second is that more, not less, precision is needed in construction contracting these days.

The reason for the first thought is that the construction industry has taken a hit lately. The news is fraught with stories of the economic downturn and its impact on construction. While the money may be hard to part with, all construction professionals should get their contracts and business practices audited regularly to avoid risk and assure, as best as is possible, that they are protected. One place to get such triage is at my firm.

If you don’t use me, please use someone else.

On the second point, clients need attorney fees provisions, indemnity clauses and to assure that a scope of work is very specifically defined. Wiggle room is not available. In tough economic times. Owners will look for something closer to perfection when money is tight than when money is not. Contractors should also. Your contract is the first line of defense. While no contract can possibly cover every contingency and contracts are only as good as those who sign them when it comes right down to it, a good base contract is the best shield.

Mr. Hill may be contacted at

Illinois Court Addresses Coverage Owed For Subcontractor’s Defective Work

Construction worker folding arms in funny pose

Brian Bassett analyzes the case Acuity Ins. Co. v. 950 W. Huron Condo. Assoc’n.

May 6, 2019
Brian Bassett - TLSS Insurance Law Blog

In Acuity Ins. Co. v. 950 W. Huron Condo. Assoc’n, 2019 IL App (1st) 180743, the Illinois Court of Appeals held that a claim against a subcontractor for damage caused to property outside the scope of its work satisfied the insuring agreement of a CGL policy.

The condominium association for the building located at 950 West Huron Street in Chicago, Illinois (“the Association”), sued its general contractor and construction manager Belgravia Group, Ltd., and Belgravia Construction Corporation (collectively “Belgravia”). The Association sought to recover for alleged defects from Belgravia’s unworkmanlike construction of the building that permitted water to permeate and cause damage.

In the Association’s complaint, it alleged that in June 2002, after the Association took possession of the building but prior to the completion of construction, Belgravia became aware of numerous conditions and defects, including extensive water infiltration of the building. After discussing the issues with Belgravia, the Association claimed that Belgravia retained contractors to provide cosmetic fixes. However, this did not address the problems and defects. The Association alleged that it spent a substantial amount of money to identify and correct the damage and that it would incur additional costs for future repairs.

Mr. Bassett may be contacted at

Estoppel Certificate? Estop and Check Your Lease

Businessman holding up a hand in a stopping gesture

Estoppel certificates are usually sent to tenants in connection with the sale or refinance of a building.

May 6, 2019
Lauren Podgorski - Snell & Wilmer Real Estate Litigation Blog

If you are leasing space in a building, there may come a time when you receive a request from your landlord to fill out and sign an estoppel certificate. Estoppel certificates are usually sent to tenants in connection with the sale or refinance of a building, and a third party may rely on the accuracy of the statements and information contained in the estoppel certificate in connection with that transaction. Estoppel certificates can range from a very simple, one-page document, to several pages.

I’ve received an estoppel certificate in the mail. What do I do now?

Consider the following:

Check your lease. Your lease may require you to deliver the signed estoppel certificate and may even give you a timeframe within which you are required to return it. A form of estoppel certificate may also be included in your lease as an exhibit. If you’ve previously agreed to a form of estoppel certificate in your lease, check to ensure the one you have received matches the form you previously agreed to and if it doesn’t make sure to review it carefully to make sure it is acceptable.

Review the estoppel certificate and confirm that all of the information is accurate. Be on the lookout for any terms or provisions that you did not agree to in your lease. If it seems like the landlord is trying to modify your lease, you likely do not need to consent to the change in this document. Cross off (or modify or delete, if you have an electronic copy) any information that is inaccurate. Fill in all blanks (if the blank is not applicable, write “N/A”), and if any exhibits are referenced in the body of the document, make sure they are actually attached.

Ms. Podgorski may be contacted at

Environmental Roundup – April 2019

Man in orange vest holding shovel by newly-planted tree, illustration

A summary of important environmental decisions issued by courts last month.

May 6, 2019
Anthony B. Cavender - Gravel2Gavel

Besides showers, this April brought a number of notable new environmental decisions issued by the federal courts. Before your mind turns to May and its flowers, here’s a summary:

1. DC Circuit. On April 23, 2019, the U.S. Court of Appeals for the DC Circuit decided the case of State of New York, et al. v. EPA. In the Clean Air Act amendments of 1990, the Congress established the Northeast Ozone Transport Region, composed of the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, the District of Columbia and a portion of Virginia. Recently, several of these states requested EPA to expand this region to include the “upwind states” of Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, Tennessee, West Virginia, and the remaining portions of Virginia. Doing so would assist the “downwind” states in complying with EPA’s 2008 Ozone standard. EPA rejected this request, which was then appealed to the DC Circuit by the states of Connecticut, Delaware, Maryland, Massachusetts, New York, Pennsylvania, Rhode Island and Vermont. Because of its unique properties, ozone created by emissions in the upwind states can be transported to the downwind states, thus allegedly hampering their ability to cope with EPA ozone standards. The court agreed that EPA has the authority to expand the Northeast Transport Ozone Transport Region, but it also has the ability to exercise its reasonable discretion not to do so. In addition, the agency’s decision to rely instead on the remedies available to it in in the Clean Air Act’s “Good Neighbor” provision was reasonable and adequately justified, and the court accordingly upheld the agency’s decision. The court also noted that other remedies may be available to the downwind states, just not this one.

2. DC Circuit. The Court also decided on April 23, 2019 the case of Air Transport Association of America v. Federal Aviation Administration. The FAA held that the payments made by the City of Portland’s airport’s utility city charges for offsite stormwater drainage and Superfund remediation was not an “impermissible diversion” of airport revenues or in violation of the “Anti-Head Tax Act,” which is codified at 49 USC Section 40116(b) and which prohibits collecting a tax on persons travelling in air commerce. Here, the charges are assessed against the airport for the use by the airport of the city’s water and sewage services. The Superfund assessment is based on the fact that the Willamette River which runs through downtown Portland could make the city a Superfund potentially responsible party, and the cty is assessing all rate payers—including the airport—a Superfund assessment. The airport is federally funded and is owned and operated by the Port of Portland, and the Port pays a combined sewer, stormwater /water bill with multiple line items including these contested items. The court notes that federal law, in particular 49 USC Section 47107(k)(2), authorizes airport revenues to be used for the operating costs of the airport receiving federal funding, and the FAA could reasonably determine that these general expenses are authorized airport “operating costs” even though the city services are provided outside the boundaries of the airport.

Mr. Cavender may be contacted at

Skender’s Modular Revolution: An Interview with Angela Spadoni

May 6, 2019
Aarni Heiskanen - AEC Business

I had the pleasure of interviewing architect Angela Spadoni, the director of residential architecture at Skender. On this podcast episode, we discuss how the company is taking the industry forward with modular construction.

Skender is one of Fast Company’s “World’s Most Innovative Companies for 2019”. Last year, the Chicago-based construction, design and manufacturing firm launched Skender Manufacturing to produce modular apartment units. We discuss the company’s new, vertically integrated business model, what makes it stand out, and the value it will provide to stakeholders.

Mr. Heiskanen may be contacted at

Alarm Cries Wolf in California Case Involving Privette Doctrine

Alarm clock in watercolor

Johnson v. The Raytheon Company, Inc. involves a false alarm. But not of the First Amendment kind.

May 6, 2019
Garret Murai - California Construction Law Blog

It’s one of the most quoted phrases in legal history: “Shouting fire in a [crowded] theater.”

It comes from the U.S. Supreme Court’s landmark 1919 decision in Schenck v. U.S. and has come to stand for the proposition that not all speech, in particular dangerous speech, is protected by the First Amendment.

The next case also involves a false alarm. But not of the First Amendment kind.

In Johnson v. The Raytheon Company, Inc., California Court of Appeal for the Second District, Case No. B281411 (March 8, 2019), a false alarm investigated by maintenance engineering staff led to a Privette Doctrine claim against a property owner when a ladder on which the maintenance staff was standing slipped on wet flooring.

Johnson v. Raytheon
Lawrence Johnson worked as a maintenance engineer for ABM Facilities Services, Inc. ABM was hired by Raytheon Company, Inc. to staff the control room at one of Raytheon’s facilities in Southern California. Among other things, control room staff monitored water cooling towers owned by Raytheon to ensure that the water in the cooling towers were maintained at minimum levels.

Mr. Murai may be contacted at

The Treasures Inside Notre Dame Cathedral

Gold coins

The cathedral, which caught fire on Monday, is a repository of European history.

May 6, 2019
James Tarmy & Eugene Reznik - Bloomberg

Paris’s Notre Dame cathedral took more than 200 years to build and just a few hours to burn. The structure’s construction began in the 12th century; six hundred years later, it was rehabilitated by Napoleon in the 1800s. In the interim, kings were crowned underneath its monumental stained glass windows even as the city around it rose, fell, and rose again.

It has served as the setting of numerous historical events, including Napoleon’s coronation in 1804. In August 1944, a special mass in the cathedral attended by General Charles de Gaulle was held to celebrate the liberation of Paris from the Nazis.

The spire contained relics of Saint Denis and Saint Genevieve, the patron saints of Paris, according to Laurent Ferri, a curator in the Division of Rare and Manuscript Collections at Cornell University and former conservateur du patrimoine at the French National Archives. The archbishop of Paris placed the relics at the summit of the church in 1935 to protect the building. “They are now likely reduced to ashes,” Ferri says.

Reprinted courtesy of James Tarmy, Bloomberg and Eugene Reznik, Bloomberg

A Digital Transformation Report: Five Emerging Trends in Construction

May 6, 2019
Stephanie Viers - Construction Executive

The construction industry is in a moment of enormous change. Business is booming — and so is the number, complexity and duration of projects. Concurrently, a serious shortage of affordable, skilled labor means that many companies are operating short-staffed.

Increasingly, construction companies are turning to technology to improve their productivity, make the most of limited resources, improve safety and document and coordinate every step of their projects. According to McKinsey, investment in construction technology has doubled in the past decade. The most innovative companies are integrating technology into their daily processes, choosing technology partners that provide intuitive tools that every team member can use. By doing so, these companies are able to remain competitive and grow revenue, reaping the benefits of more comprehensive real-time reporting, resulting in savvier asset allocation and project planning.

Reprinted courtesy of Stephanie Viers, Construction Executive, a publication of Associated Builders and Contractors. All rights reserved.

Ms Viers may be contacted at

Newmeyer & Dillion Announces New Partner Bahaar Cadambi

Gold stars and circles on black background

Bahaar Cadambi has been elected to partnership at the Newmeyer & Dillion firm.

May 6, 2019
Newmeyer & Dillion

Prominent business and real estate law firm Newmeyer & Dillion LLP is pleased to announce that Newport Beach attorney Bahaar Cadambi has been elected to partnership.

"Bahaar has worked hard to become an integral part of the firm's litigation practice, delivering exceptional value to her colleagues and clients at every opportunity," said the firm's Managing Partner, Paul Tetzloff, "We are proud to count her among our partners and look forward to her continued success and contributions."

Cadambi concentrates her practice in business, insurance, and real estate litigation. She represents businesses, homebuilders, developers, and general contractors in complex, multi-party real estate, construction defect, and insurance disputes. She also represents individuals and businesses across a variety of business litigation matters. Her approach to litigation ensures that clients are informed of all potential strategies, the consequences of those strategies, and how the implementation of those strategies will affect their business.

Passionate about the legal community, Cadambi is an adjunct professor at the University of Southern California Gould School of Law and an active member of CREW (Commercial Real Estate Women Orange County). She is also a Barry's Bootcamp and yoga enthusiast, lover of all things interior design, avid traveler, devoted wife, and favorite aunt to two energetic nieces and one cheerful nephew.

Bahaar earned her B.A. from the University of California, Los Angeles and her J.D. from the University of California, Hastings College of Law. Prior to joining Newmeyer & Dillion, she served as a Judicial Extern for the Honorable William Alsup in the U.S. District Court for the Northern District of California.

Bahaar Cadambi:

    Practice Areas
  • Business Litigation
  • Construction Litigation
  • Insurance Law

About Newmeyer & Dillion
For almost 35 years, Newmeyer & Dillion has delivered creative and outstanding legal solutions and trial results for a wide array of clients. With over 70 attorneys practicing in all aspects of business, employment, real estate, privacy & data security and insurance law, Newmeyer & Dillion delivers legal services tailored to meet each client's needs. Headquartered in Newport Beach, California, with offices in Walnut Creek, California and Las Vegas, Nevada, Newmeyer & Dillion attorneys are recognized by The Best Lawyers in America©, and Super Lawyers as top tier and some of the best lawyers in California, and have been given Martindale-Hubbell Peer Review's AV Preeminent® highest rating. For additional information, call 949.854.7000 or visit


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