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M. Claims & Litigation History <br />City of Sunny Isles Beach | Request for Qualifications No. 15-08-02 <br />September 23, 2015 <br />Page 55 <br />Response Hensel Phelps is or within the past five years has been involved in the following <br />significant litigation matters related to Hensel Phelps’ project work. <br />Hensel Phelps v. Bond <br />Safeguard, Case No. <br />14-cv-02495-KLM <br />This action was filed in October 2014 in US District Court in Denver, Colorado, by Hensel <br />Phelps against Bond Safeguard Insurance Company, as surety for Trainor Glass, to recover <br />costs incurred by Hensel Phelps correcting defects in glass work installed by Trainor on the <br />Denver Courthouse Project. Trainor ceased operations and was unable to perform and Hensel <br />Phelps filed suit to recover the costs incurred performing on Trainor’s behalf when the surety <br />refused the reimburse Hensel Phelps for these costs. The matter is currently in the early stages <br />of discovery. <br />Cupertino Electric, Inc. v. <br />Hensel Phelps, CGC-14- <br />542331 <br />This action was filed in October 2014 in San Francisco County, California, by Cupertino Electric, <br />Inc. seeking to recover funds allegedly due and owing on a Stop Notice in the amount of <br />$5,108,582.00 for work performed on the San Francisco Airport Terminal 3 project. The parties <br />mutually agreed to stay the action while awaiting payment from the Owner and such payments <br />have significantly reduced the amount of the claim. The parties continue to work together to <br />facilitate payment of the remaining amounts arising out of an insurance claim. <br />Blake’s Painting v. <br />Hensel Phelps, Case No. <br />9:14-CV-3020-SB <br />This Miller Act case was filed in August 2014 in a South Carolina federal court by a painting <br />subcontractor on the P444 and P454 Marine Training Simulator Facility and Hangar at the <br />Marine Corps Air Station, Beaufort, South Carolina. The suit contends that Hensel Phelps <br />has not paid Blake’s for work performed on the project. Hensel Phelps has filed an answer <br />denying the claim given that Blake’s failed to perform its contractual duties by failing to staff <br />the work and adhere to project specifications, allowing HPCC to withhold payment in order to <br />supplement Blake’s work. The case has been stayed pending arbitration, which is scheduled <br />for sometime in 2016. <br />Radonich Corp. v. <br />Cupertino Elec., et al., <br />Case No. 114cv264333 <br />This action was initially filed in April 2014 in Santa Clara, California, state court over a claim <br />regarding the Santa Clara Medical Center Seismic Safety Project. This case stems from <br />conflicting bridging documents provided by the owner related to the installation of a particular <br />type of cable. Cal Coast Telecom (Radonich) has sued Cupertino over the non-payment of <br />the proper cable and attendant labor. A claim has been made with the owner, the resolution of <br />which is not complete. Cupertino sued Hensel Phelps on an implied indemnity theory related <br />to the claim. The case will be arbitrated sometime in 2016. <br />Beeler Barney & <br />Associates Masonry <br />Contractors, Inc. v. Hensel <br />Phelps, et. al., Case No. <br />1:14-CV-012-WKW <br />This matter was filed in January 2014 in an Alabama federal court. The action is a Miller <br />Act claim brought by a subcontractor stemming from a fatal accident, for which a different <br />subcontractor was responsible, at a project in Ft. Rucker, Alabama. BBA received payment <br />as part of a project-wide builder’s risk insurance claim, but alleges that the amount was not <br />sufficient to cover its costs. Hensel Phelps disputes BBA’s claim, countering that its costs were <br />due to its own failures, and that its accident-related costs were compensated by insurance. <br />The parties agreed to mediate, which resulted in a global settlement of which HP contributed <br />$7,500. Incidentally, there was a companion case with the same facts, Covenant v. Hensel <br />Phelps, that was stayed in the same court and also settled at the same mediation. <br />Westfield Insurance Co. v. <br />HPCC and Noorda Sheet <br />Metal Co., Case No. 13- <br />CV-02419 <br />This matter is a declaratory action filed in September 2013 in the federal district of Colorado <br />over the “HAATS” project at the Eagle County Airport in Gypsum, Colorado. The plaintiff <br />surety issued performance and payment bonds on behalf of Noorda, the metal roof system <br />subcontractor. Noorda experienced financial difficulties that led HPCC to terminate Noorda. <br />Westfield stepped in under the bonds and HPCC agreed to reinstate Noorda. HPCC defaulted <br />Noorda a second time for performance issues after its work failed. Westfield filed this action for <br />a determination of rights related to HPCC’s termination of Noorda, HPCC’s testing procedures, <br />and HPCC’s requirements for repair. All other claims are against other parties. HPCC filed <br />a motion to arbitrate and the matter was resovled in mediation with Westfield agreeing to <br />reimburse Hensel Phelps for costs incurred in correcting Noorda’s work in an amount in excess <br />of $800,000. <br />The Mark Condominium <br />Owners Association v. <br />The Mark Condominiums <br />LLC, Case No. 37-2013- <br />00049168 <br />This action commenced in July 2013 in San Diego County, California, by the Home Owners <br />Association of the Mark Condominium project in San Diego, California against the Developer, <br />Designer, Hensel Phelps, and several subcontractors and material suppliers alleging <br />construction defects and warranty issues. Most of the defendants were covered by an Owner <br />Controlled Insurance Program which assumed defense of the matter on behalf of all named <br />insureds. The case is in its infancy and is being investigated. Discovery has yet to begin.