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1 <br /> QUALIFICATION STATEMENT NO. 11 <br /> DRC EMERGENCY SERVICES,LLC FIVE YEAR LITIGATION <br /> (Updated and Revised:May 2,2018) <br /> The following is a list of all litigation involving DRC Emergency Services, LLC ("DRCES") related to emergency <br /> disaster recovery and management services pending or resolved in a five-year period commencing May 2,2013 and <br /> ending May 2,2018. <br /> ALABAMA <br /> 1. Fuzzell v. DRC Emergency Services,LLC,No.14-904190,Jefferson County Cir. Ct,AL. Claim by Stewart G.Fuzzell for <br /> breach of an alleged verbal employment agreement which induded a purported verbal revenue share. Plaintiff claimed$26 <br /> million.Mattel settled and dismissed on April 19,2016. <br /> 2. Cahaba Disaster Recovery, LLC v. DRC Emergency Services, LLC, Civil Action No. 01-CV-2015-903953, Circuit Court, <br /> Jefferson County,Alabama removed to US.Dist.Court for the Northern Dist Of Alabama,Case No.15-2096.Payment claim for <br /> $2477,68029 by plaintiff for work allegedly performed on a Joplin, MO tornado debris removal project Matter settled and <br /> dismissed on April 22,2016. <br /> 3. DRC Emergency Services, LLC and Liberty Mutual Insurance Company v. R. Baker, Inc., Civil Action No. 14- <br /> 2281,United States District Court for the Northern District of Alabama,Birmingham Division.Declaratory action <br /> filed by DRCES and its surety against a sub-subcontractor regarding non-liability for lower tier sub- <br /> subcontractor claims. Franklin County and Town of Phil Campbell tornado recovery projects. Matter settled <br /> and was dismissed on February 12,2016. <br /> 4. B&B Environmental Services, et al v. DRC Emergency Services, LLC, et al, Mobile County, Alabama Circuit <br /> Court, Case No. 14-903439. Unquantified suit by lower tier sub-subcontractors for payment claiming existence <br /> a partnership/joint venture between DRCES and its former subcontractor. Multiple disaster recovery projects. <br /> Matter settled and dismissed on March 21,2016. <br /> 5. Weston v. DRC Emergency Services, LLC, et al, Civil Action No. 13-900067, Marshall County, Alabama <br /> Circuit Court. Unquantified personal injury/wrongful death claim. Decedent was an employee of a lower-tier <br /> subcontractor. OSHA investigated and issued no citation. Alabama Dept. of Conservation tornado recovery <br /> project. All claims against DRCES were dismissed (no liability) on January 12, 2015. <br /> ® 6. Luc Raymond v.DRC Emergency Services,LLC,Case No.2012-CV-901342,Mobile County,Alabama Circuit <br /> ® Court.Lawsuit for earthquake related work performed in Haiti. Case Settled for$175,000 and dismissed July 24, <br /> 2014. <br /> 7. Group CG Builders v. DRC Emergency Services, LLC, et al, United States District Court for the Southern <br /> District of Alabama, Case No. 11-729, on appeal to the U.S. 11th Circuit Court of Appeals, Case No. 12-14586. <br /> $900,000 claim by sub-subcontractor for disaster recovery work performed in Haiti.Suit in United States against <br /> DRCES dismissed by district court; dismissal affirmed on appeal August 12, 2013. Suit in Dominican Republic <br /> pending. <br /> 8. Black Warrior Solid Waste Authority v. DRC Emergency Services, LLC,Tuscaloosa County, Alabama Circuit <br /> Court, Case No. 2013-900472. $30,000 collection dispute involving disposal fees on Tuscaloosa tornado recovery <br /> project. Case settled and dismissed on August 15,2013. <br /> 9. Acton Plumbing & Heating Co., Inc. v. DRC Emergency Services, LLC, Case No. 2014-904235, Jefferson <br /> County,Alabama Circuit Court. Claim by lower-tier sub-subcontractor for Birmingham tornado recovery work. <br /> Case settled for$17,896.29 and dismissed on November 12, 2014. <br /> ODRC <br /> DRC Emergency Services,LLC 108 EMERGENCY sEa�,�Es <br /> I RFP No.18-04-02 ► <br />