714.701.9180
CONSTRUCTION DEFECT NEWS
Lawyer talking to judge illustration

Foreseeability is a tort concept that tends to permeate several aspects of legal analysis.

Illinois Federal Court Determines if Damages Are Too Remote

Monday, July 13, 2020 — Lian Skaf - The Subrogation Strategist

Foreseeability is a tort concept that tends to permeate several aspects of legal analysis, often causing confusion in litigants’ interpretation of, and courts’ application of, foreseeability to their cases. In Cincinnati Ins. Co. v. Progress Rail Services. Corp., 2020 U.S. Dist. LEXIS 73967 (C.D. Ill.), the United States District Court for the Central District of Illinois took on the task of analyzing a case dealing with foreseeability issues to determine if the defendant owed the plaintiff a duty and if the damages were so remote as to violate public policy. The court held that since the defendant’s actions contributed to the risk of harm to the plaintiff and the facts satisfied the four-prong duty test, the defendant owed the plaintiff’s subrogor a duty of reasonable care. It also held that the plaintiff’s damage claim did not open the defendant up to liability that would violate public policy.

In the case, an employee of defendant Progress Rail Services Corporation (Progress Rail) was operating a crane at Progress Rail’s Galesburg location on May 7, 2018. The employee struck an overhead power line while working, causing a power disruption to nearby businesses. The plaintiff’s subrogor, Midstate Manufacturing Company (Midstate), was one of the affected businesses, reporting that its Amada hydraulic punch was damaged. Midstate submitted a property damage claim to its carrier, Cincinnati Insurance Company (Cincinnati), who reimbursed it under its policy. Subsequent to its payment, Cincinnati filed suit against Progress Rail in Illinois state court. Progress Rail then removed the case to federal court and filed a motion to dismiss.

Reprinted courtesy of Lian Skaf, White and Williams LLP

Mr. Skaf may be contacted at skafl@whiteandwilliams.com

Read the full story…
Statute of liberty weighing scales

Attorneys Lorelie S. Masters and Patrick M. McDermott discuss Duke Energy Carolinas, LLC v. AG Insurance SA/NV.

North Carolina Court Rules In Favor Of All Sums

Monday, July 13, 2020 — Lorelie S. Masters & Patrick M. McDermott - Hunton Andrews Kurth

A North Carolina court recently ruled in favor of all sums allocation. Duke Energy Carolinas, LLC v. AG Insurance SA/NV, No. 17 CVS 5594 (N.C. Sup. Ct.). In that case, Duke Energy is seeking coverage for “liabilities linked to coal combustion residuals (‘CCRs’), i.e., coal ash, at fifteen Duke-owned power plants in North and South Carolina.” In a recent summary judgment decision, the court resolved a dispute between Duke and TIG Insurance Company, as successor to Ranger Insurance Company, about whether all sums allocation or pro rata allocation applied.

The court found that “the non-cumulation provisions make plain” that all sums allocation applied. It also noted that “a large majority of the courts in other jurisdictions that have considered this issue have recognized that non-cumulation provisions such as those here compel all sums rather than pro rata allocation.” The decisions to the contrary, according to the court, had ruled “done so on public policy grounds” and not based on “the application of the rules of contract interpretation.”

Reprinted courtesy of Lorelie S. Masters, Hunton Andrews Kurth and Patrick M. McDermott, Hunton Andrews Kurth
Ms. Masters may be contacted at lmasters@HuntonAK.com
Mr. McDermott may be contacted at pmcdermott@HuntonAK.com


Read the full story…
Close up on eyes

More than 100,000 small businesses in America have closed their doors permanently due to the coronavirus.

A Glimpse Into Post-Judgment Collections and Perhaps the Near Future?

Monday, July 13, 2020 — Garret Murai - California Construction Law Blog

According to a recent study conducted by the Harvard University, the University of Chicago, and the University of Illinois, more than 100,000 small businesses (firms with fewer than 500 employees) representing 2% of small businesses in the America have closed their doors permanently due to the coronavirus. The next case, although about events occurring before COVID-19, provides a glimpse of what litigation may look like in the intervening months and years as companies struggle to keep their doors open.

The Wanke Case
Waterproofing company Wanke, Industrial, Commercial, Residential, Inc. sued a former employee, Scott Keck, and his competing company, WP Solutions, Inc., for trade secret misappropriation and obtained a judgment for $1,190,929.

At the time, general contractor AV Builder Corp. had hired WP Solutions as a waterproofing subcontractor on fire residential and commercial projects. In the face of the judgment obtained by Wanke, Keck declared bankruptcy and dissolved WP Solutions.

Reprinted courtesy of Garret Murai, Nomos LLP

Mr. Murai may be contacted at gmurai@nomosllp.com

Read the full story…
714.701.9180

Protecting Construction Workers from the Dangers of Hydrogen Sulfide

July 13, 2020 — Chris Detillier - Construction Executive

Construction is one of the most dangerous professions, with one in five worker fatalities in 2018 occurring within the industry. The dangers of a construction site extend beyond the fatal four dangers reported by OSHA (falls, electrocution, struck-by-objects and caught-in-between) to those that cannot be easily spotted. Known as the silent killer, Hydrogen Sulfide, commonly referred to as H2S or sour gas, is the second most common cause of workplace gas inhalation fatalities following carbon monoxide. The colorless, flammable gas is naturally produced by the decomposition of organic material and is also emitted as a by-product of many industrial processes.

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

714.701.9180

COVID-19 Claim for Business Interruption Remanded to State Court

July 13, 2020 — Tred R. Eyerly - Insurance Law Hawaii

Acknowledging there was not yet a body of case law developed by the state court, the federal district court remanded the claim. Dianoia's Eatery, LLC v. Motorists Mutual Ins. Co., Civil Action No. 20-706 (W.D. Pa. May 19, 2020).

Dianoia's filed a complaint in state court against Motorists Mutual seeking a declaratory judgment for coverage for business interruption losses due to COVID-19 shut down orders. Motorists Mutual removed to federal district court.

Mr. Eyerly may be contacted at te@hawaiilawyer.com

714.701.9180

Face-Covering Policy Remains Flexible As Hoar Construction Confronts Two Virus-Troubled Projects

July 13, 2020 — Richard Korman - Engineering News-Record

This spring, Hoar Construction has found itself on both sides of the face-covering challenge.
As guidance on virus protections for workers evolved during the spring, contractors in many parts of the U.S. chose or were compelled by state or local rules or unions to go beyond federal guidance and require workers to use a face covering of some kind on the jobsite.

Richard Korman, Engineering News-Record

Mr. Korman may be contacted at kormanr@enr.com

Read the full story...

714.701.9180

Video Arbitration: What to Consider Before Jumping In

July 13, 2020 — Beverley BevenFlorez – CDJ Staff

The American Bar Association presents a webinar on how to deal with virtual arbitration hearings in the era of Covid-19. Panelists include “two litigators who gained their experience in virtual hearings after their in-person hearing in New York City was shut down abruptly due to the pandemic” as well as a “a senior representative from the American Arbitration Association.” The webinar will cover “the legal issues presented by online hearings, applicable arbitral institution rules, and discuss important considerations and best practices for conducting an arbitration hearing remotely.”

August 19th, 2020
Webinar

714.701.9180
Featured Experts For More Visit Us At:
www.constructiondefectjournal.com

Roofing and Waterproofing Consultant Testifying Expert Witness area area area

Consulting General Contractor and Building Expert Witness Specializing in Construction Remediation and defect claims area areaarea

Builders Standard of Care Expert Witness and Consulting General Contractor area area area

Person working on laptop

Given the inherent difficulties of convening juries in a world of social distancing, it is likely that multiple jurisdictions will be unable to conduct live jury trials for at least the next several months.

Virtual Jury Trials: The Next Wave of Remote Legal Practice

Monday, July 13, 2020 — David R. Zaslow & Mark Paladino - White and Williams

One of the most obvious and unavoidable results of the COVID-19 crisis has been the postponement of jury service and, by extension, all jury trials. Given the inherent difficulties of convening juries in a world of social distancing, it is likely that multiple jurisdictions will be unable to conduct live jury trials for at least the next several months.

Recognizing the mounting delay and substantial docket backlog that is attendant to several months without jury trials, one court most recently permitted the litigants, upon consent, to try a new innovation – the nation’s first virtual jury trial conducted entirely on the Zoom platform. More than two dozen potential jurors in Collin County, Texas attended jury selection from home by smartphone, laptop, and tablet, a process that was streamed live on YouTube. The presiding judge occasionally provided prospective jurors technical advice on how to best use their devices.

Once selected, the jurors virtually attended a one-day, “summary jury trial” of an insurance dispute in which they heard a condensed version of the case and delivered a non-binding verdict. The parties were then able to gauge how their cases would fare before a jury in a full-scale trial and, with that insight, agreed to proceed to a mediation in an attempt to reach a resolution. Court officials further touted the abbreviated, non-binding experience as an ideal test for the viability of remotely holding jury trials that would result in a final judgment. This real-world test, albeit in a non-binding exercise, may be an indication of things to come, as courts in Indiana and Arizona have already communicated an intention to conduct jury trials remotely once able.

Reprinted courtesy of David R. Zaslow, White and Williams and Mark Paladino, White and Williams
Mr. Zaslow may be contacted at zaslowd@whiteandwilliams.com
Mr. Paladino may be contacted at paladinom@whiteandwilliams.com


Read the full story…
Businessman holding red umbrella in yellow meadow

An insurance company avoiding paying a claim after it misrepresented the coverage of a crime policy it sold.

Crime Policy Insurance Quotes Falsely Represented the Scope of its Coverage

Monday, July 13, 2020 — Brian J Clifford - Saxe Doernberger & Vita

An Indiana businessman found out the hard way how far his insurance company was willing to go to avoid paying a claim after it misrepresented the coverage of a crime policy it sold to him. The quote for the policy indicated that it included coverage for losses resulting from computer hacking. Despite this representation, when the policyholder’s bank accounts were hacked, the insurer denied coverage on the ground that there was no provision for hacking coverage in the policy. Fortunately, the Indiana Court of Appeals recognized the insured’s right to argue before a jury that the insurer’s quotes falsely represented the scope of its coverage.

In Metal Pro Roofing, LLC v. Cincinnati Ins. Co., Richard Cornett, principal of Metal Pro Roofing, LLC and Cornett Restoration, LLC (the “LLCs”), purchased a Cincinnati Insurance Company CinciPlus Crime XC+ Policy (the “Policy”). At the time Mr. Cornett purchased this coverage, and during all subsequent renewals, Cincinnati issued insurance quotes that stated:

Cincinnati can insure your money and securities while at your premises, inside your bank and even off site in the custody of a courier. While you’ve taken precautions to protect your money and securities, you run the risk of loss from employees, robbers, burglars, computer hackers and even physical perils such as fire.

Give yourself peace of mind with Cincinnati’s crime coverage to insure the money and securities you worked so hard to earn.

Crime Expanded Coverage (XC®)Plus Endorsement $125.00.

(Emphasis added.)

Reprinted courtesy of Brian J Clifford, Saxe Doernberger & Vita

Mr. Clifford may be contacted at bjc@sdvlaw.com

Read the full story…
Businessman holding money in hands

Ted R. Gropman, Partner, and Cindy J. Lee, Associate, analyze Crosno Construction, Inc. v. Travelers Casualty & Surety Company of America.

Court Provides Guidance on ‘Pay-When-Paid’ Provisions in Construction Subcontracts

Monday, July 13, 2020 — Ted R. Gropman & Cindy J. Lee - ConsensusDocs

On April 17, the California Court of Appeal decided Crosno Construction, Inc. v. Travelers Casualty & Surety Company of America,1 effectively narrowing the scope of enforceable “pay-when-paid” provisions in construction subcontracts to the extent the subcontractor seeks recovery against a general contractor’s payment bond surety. Although the Crosno case involved a public works project, the rationale and holding should apply with equal force to private works projects. Basing the bulk of its decision on the Wm. R. Clarke Corp. v. Safeco Insurance Co.2 case, the court found that an open-ended “pay-when-paid” provision in a subcontract is not enforceable against a subcontractor that seeks to recover on a public works payment bond claim. This article discusses the Crosno decision and the implications for contractors on both sides of the contract moving forward.

Brief Case Summary

In Crosno, general contractor Clark Bros., Inc. contracted with the North Edwards Water District (the District) to build an arsenic removal water treatment plant. Clark hired steel storage tank subcontractor Crosno Construction, Inc. to build and coat two steel reservoir tanks. Clark and Crosno’s subcontract included a “pay-when-paid” provision, which stated that Clark would pay Crosno within a “reasonable time” of receiving payments from the owner, but “in no event less than the time Contractor and Subcontractor require to pursue to conclusion their legal remedies against Owner or other responsible party to obtain payment.” After Crosno completed its work, a dispute arose between Clark and the District, and the District withheld payment from Clark (including the monies earmarked for Clark’s subcontractors). Clark sued the District for payment, and Crosno filed its own action against Travelers Casualty and Surety Company of America, the surety on Clark’s statutory public works payment bond, for recovery of the unpaid subcontract balance. Travelers rejected Crosno’s bond claim as premature, invoking the “pay-when-paid” subcontract language and pointing to Clark’s pending payment action against the District. The issue on appeal was whether the “pay-when-paid” provision in the subcontract blocked Crosno from recovering under the payment bond from Travelers while Clark’s lawsuit against the District was still pending.

Reprinted courtesy of Ted R. Gropman, Pepper Hamilton LLP and Cindy J. Lee, Pepper Hamilton LLP
Mr. Gropman may be contacted at ted.gropman@troutman.com
Ms. Lee may be contacted at cindy.lee@troutman.com


Read the full story…
714.701.9180
CONSTRUCTION DEFECT NEWS
Profile of brain inside body

Hedging a position on a contingent event is not the right course of action.

Think Twice Before Hedging A Position Or Defense On A Speculative Event Or Occurrence

Monday, July 13, 2020 — David Adelstein - Florida Construction Legal Updates

Sometimes, hedging a position on a potential occurrence is not prudent. Stated differently, hedging a position on a contingent event is not the right course of action. The reason being is that a potential occurrence or contingent event is SPECULATIVE. The occurrence or event may not take place and, even if it does take place, the impact is unknown.

An example of hedging a defense on such a potential occurrence or contingent event can be found in a construction dispute involving a federal project out of the Eastern District of Virginia, U.S. f/u/b/o Champco, Inc. v. Arch Insurance Co., 2020 WL 1644565 (E.D.Va. 2020). In this case, the prime contractor hired a subcontractor to perform electrical work, under one subcontract, and install a security system, under a separate subcontract. The subcontractor claimed it was owed money under the two subcontracts and instituted a lawsuit against the prime contractor’s Miller Act payment bond. The prime contractor had issued the subcontractor an approximate $71,000 back-charge for delays. While the subcontractor did not accept the back-charge, it moved for summary judgment claiming that the liability for the back-charge can be resolved at trial as there is still over $300,000 in contract balance that should be paid to it. The prime contractor countered that the delays caused by the subcontractor could be greater than $71,000 based on a negative evaluation in the Contractor Performance Assessment Reporting System (“CPARS”). A negative CPARS rating by the federal government due to the delays caused by the subcontractor would result in a (potential) loss of business with the federal government (i.e., lost profit) to the prime contractor. The main problem for the prime contractor: a negative CPARs rating was entirely speculative as there had not been a negative CPARs rating and, even if there was, the impact a negative rating would have on the prime contractor’s future business with the federal government was unknown. To this point, the district court stated:

In this case, [prime contractor’s] claim for damages is wholly speculative. [Prime contractor] has not produced any evidence that its stated condition precedent—a negative CPARS rating—will actually occur and will have a negative impact on its future federal contracting endeavors. Specifically, [prime contractor] has not identified any facts that indicate that it will be subject to a negative CPARS rating or any indication of the Navy’s dissatisfaction with its work as the prime contractor on the Project… Further, a CPARS rating is only one aspect taken into consideration when federal contracts are awarded. In sum, there is no evidence of the following: (1) a negative CPARS rating issued to [prime contractor]; (2) [prime contractor’s] hypothetical negative rating will be the result of the delay [prime contractor] alleges was caused by [subcontractor]; or (3) [prime contractor’s] hypothetical negative CPARS rating will result in future lost profits.

U.S. f/u/b/o Champco, Inc., supra, at *2 (internal citation omitted).

Reprinted courtesy of David Adelstein, Kirwin Norris, P.A.

Mr. Adelstein may be contacted at dma@kirwinnorris.com

Read the full story…
Worker with shovel by tree illustration environment

The U.S. Court of Appeals for the Ninth Circuit decided three significant environmental law cases.

A Court-Side Seat: Environmental Developments on the Ninth Circuit

Monday, July 13, 2020 — Anthony B. Cavender - Gravel2Gavel

On May 26, 2020, the U.S. Court of Appeals for the Ninth Circuit decided three significant environmental law cases. Two of these cases involved whether global warming tort cases could be brought in California state courts on, for example, a public nuisance claim, and whether the defendant energy companies had the right to have them removed to the federal courts.

County of San Mateo, et al. v. Chevron Corp., et al. and City of Oakland v. BP PLC, et al.
While acknowledging the immensity of the legal issues, the Ninth Circuit held that the federal removal statutes did not permit these cases to be removed to the federal courts. For one thing, state court jurisdiction was not preempted by the Clean Air Act. Accordingly, the court affirmed the ruling of Federal Judge Chhabria in the Chevron case, and vacated Judge Alsup’s ruling in the BP case that he had jurisdiction to hear this case pursuant to federal common law, and then to dismiss it. The court also remanded the case to Judge Alsup, and directed him to determine if there was an “alternate basis” for federal court jurisdiction based on the pleadings that an issue of ”navigable waters” was a concern.

Reprinted courtesy of Anthony B. Cavender, Pillsbury

Mr. Cavender may be contacted at anthony.cavender@pillsburylaw.com

Read the full story…
3d characters in race with one crossing red finish line

This is Valerie’s third JD Supra Readers’ Choice Award and Christopher’s second.

Valerie A. Moore and Christopher Kendrick are JD Supra’s 2020 Readers’ Choice Award Recipients

Monday, July 13, 2020 — Christopher Kendrick & Valerie A. Moore – Haight Brown & Bonesteel LLP

Haight is thrilled to announce that Valerie A. Moore and Christopher Kendrick are receiving JD Supra’s 2020 Readers’ Choice Awards. The award acknowledges top authors and firms for their thought leadership in key topics during 2019. This is Valerie’s third JD Supra Readers’ Choice Award and Christopher’s second.

Specifically, Valerie and Chris receive the following recognition for the level of visibility and engagement our firm and authors attained in 2019, from among thousands of others, with readers of these topics:

Valerie Moore – a top author in Insurance
Christopher Kendrick – a top author in Insurance

JD Supra’s Readers Choice Awards
The Readers’ Choice Awards recognize top authors and firms who were read by C-suite executives, in-house counsel, media and other professionals across the JD Supra platform during 2019.

Reprinted courtesy of Christopher Kendrick, Haight Brown & Bonesteel LLP and Valerie A. Moore, Haight Brown & Bonesteel LLP
Mr. Kendrick may be contacted at ckendrick@hbblaw.com
Ms. Moore may be contacted at vmoore@hbblaw.com


Read the full story…

Assessment and Repair of a Precast Parking Deck with Construction Defects

714.701.9180
CONSTRUCTION DEFECT NEWS
Red rules binder

OSHA issued more comprehensive guidance for the construction industry.

OSHA Issues COVID-19 Guidance for Construction Industry

Monday, July 13, 2020 — Garret Murai - California Construction Law Blog

This past month, after remaining relatively quiet following the coronavirus outbreak, OSHA began issuing industry-specific guidance on how to deal with the coronavirus in the workplace.

Until this month, the only construction industry specific guidance issued by OSHA was an OSHA Alert entitled COVID-19 Guidance for the Construction Workforce, a one page document providing little more guidance than that workers should stay home if sick, wear masks and frequently wash hands to prevent spreading and catching the coronavirus, and to sanitize tools and work areas.

Early this month, OSHA issued more comprehensive guidance for the construction industry. The guidance, as noted in the preface by OSHA is simply guidance, “is not a standard or regulation” and “creates no legal obligations. The guidance supplements general guidance applicable to all workplaces issued earlier by OSHA.

Reprinted courtesy of Garret Murai, Nomos LLP

Mr. Murai may be contacted at gmurai@nomosllp.com

Read the full story…


Under construction black and yellow stripes

When you foreclose on a construction lien, there are a couple of pointers to remember.

Foreclosing Junior Lienholders and Recording A Lis Pendens

Monday, July 13, 2020 — David Adelstein - Florida Construction Legal Updates

When you foreclose on a construction lien, there are a couple of pointers to remember.

First, you want to make sure you include junior lienholders or interests you are looking to foreclose (or you want to be in a position to amend the foreclosure lawsuit to identify later). The reason being is you want to foreclose their interests to the property. “[J]unior interest holders are a narrow class of mortgagees whose interest in the underlying property is recorded after the foreclosing contractor’s claim of lien is filed. This class is routinely joined to the construction lien enforcement action under section 713.26 to allow the construction lienor to foreclose out the junior lienholder’s interest in the property encumbered by the construction lien.” See Decks N Sunch Marine, infra.

Second, you want to record a lis pendens with the lien foreclosure lawsuit. Failure to do so could be problematic because Florida Statute s. 713.22(1) provides in part, “A lien that has been continued beyond the 1-year period by the commencement of an action is not enforceable against creditors or subsequent purchasers for a valuable consideration and without notice, unless a notice of lis pendens is recorded.”

Reprinted courtesy of David Adelstein, Kirwin Norris, P.A.

Mr. Adelstein may be contacted at dma@kirwinnorris.com

Read the full story…


Virtual design tunnel

What contractors most need to know about the new system.

U.S. Department of Defense Institutes New Cybersecurity Maturity Model Certification

Monday, July 13, 2020 — Joseph N. Frost - Peckar & Abramson

Contractors doing business with the Federal Government, particularly with the Department of Defense (“DoD”), commonly handle sensitive information that is not intended to be disseminated. Controlled Unclassified Information (“CUI”) is one such type and is more specifically defined as “information that requires safeguarding or dissemination controls pursuant to and consistent with laws, regulations and government-wide policies.”1 Because some DoD contracts require contractors to handle CUI, certain safeguards have been put in place to ensure its security. This article briefly touches on the current cybersecurity protocols, followed by a discussion of the new system being developed by the DoD, and what contractors most need to know about the new system.

The Defense Federal Acquisition Regulation Supplement (“DFARS”) has long required contractors to comply with certain cybersecurity standards, as published by the National Institute of Standards and Technology (“NIST”). Specifically, DFARS sought to implement the cybersecurity framework found in NIST Special Publication (“SP”) 800-171, entitled “Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations.” NIST SP 800-171 sets forth fourteen (14) families of recommended security requirements for protecting the confidentiality of CUI in nonfederal systems and organizations, including, among others, access control, audit and accountability, incident response, personnel security, and system and information integrity. However, after a series of data breaches, the DoD reassessed the efficacy of the continued use of NIST SP 800-171 and ultimately decided to institute a new methodology to ensure the security of CUI.

Reprinted courtesy of Joseph N. Frost, Peckar & Abramson

Mr. Frost may be contacted at jfrost@pecklaw.com

Read the full story…


Woman with cold working from home

Attorney Melissa (Powar) Clarke highlights some key issues that arise when managing remote workers.

Issues to Watch Out for When Managing Remote Workers

Monday, July 13, 2020 — Melissa (Powar) Clarke - Payne & Fears

Managing remote workers comes with its share of challenges. The complexities of setting and articulating expectations in a remote work environment – and providing feedback about performance tied to those expectations - adds an additional burden to our already-crowded work lives, particularly for managers who are new to remote supervisory roles.

This article highlights some key issues that arise when managing remote workers.

Issue 1: Insufficient feedback

Annual reviews are not enough. Data clearly reflects that employees who receive regular feedback are happier, and more productive, in their roles. Employees require a “continuous feedback loop” to grow and improve. While many companies started migrating toward continuous feedback before the pandemic, remote work further increases the need for more frequent (formal and informal) check-ins. Organizations must provide management with a toolkit for providing – and receiving – constant feedback, and this toolkit should take into account changes in work styles and modalities of communication when employees are remote. Given the ease with which we can give face-to-face feedback compared to “virtual” feedback, this toolkit becomes even more important when only some employees are remote and others have returned onsite.

Reprinted courtesy of Melissa (Powar) Clarke, Payne & Fears

Ms. Clarke may be contacted at mec@paynefears.com

Read the full story…


Builders Standard of Care Expert Witness and Consulting General Contractor area area area

Builders Standard of Care Expert Witness and Consulting General Contractor area area area

Builders Standard of Care Expert Witness and Consulting General Contractor area area area

714.701.9180
714.701.9180
714.701.9180
Construction Defect Journal is aggregated from a variety of news sources, article submissions, contributors, and information from industry professionals.
No content on this site should be construed as legal advice or expert opinion. By viewing this site you agree to be bound by its terms and conditions CONSTRUCTION NEWS constructiondefecteminars.html constructionDefectChannel.html contactCDJ.html