Preview
Filing# 137225118 E-Filed 10/25/2021 04:38:00 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
SAGE BEACH CONDOMINIUM
ASSOCIATION, INC., a Florida not for profit
corporation
CASE NO.: CACE-20017530
Plaintiff.
DIVISION: 07
The Honorable Jack Tatur
VS.
CONSOLIDATED WITH
PMG DRIFTWOOD, LLC, a Florida limited
CASE NO.: CACE-20017790
liability
company;
GLENEWINKEL
CONSTRUCTION COMPANY, LLC, a Florida
limited
liabilitycompany; URVANX, INC., a
Florida
corporation;
SHAMROCK
ENGINEERING, CORP., a Florida corporation;
CALVIN GIORDANO & ASSOCIATES, INC., a
Florida Corporation;and CHM STRUCTURAL
ENGINEERS, LLC, a Florida limited liability
company; ARMSTRONG AIR CONDITION &
HEATING OF CENTRAL FLORIDA, INC., a
Florida corporation;ASSOCIATED STEEL AND
ALUMINIUM, INC., a Florida corporation;B.
CODY PLUMBING, INC., a Florida corporation;
BRADFORD PRODUCTS, LLC, a North Carolina
limited liability
company; BUILDING ENVELOPE
SYSTEMS,
INC.,
a
Florida
corporation;
CONSTRUCTION SPECIALTIES, INC. a New
Jersey corporation; DUN-RITE
MARBLE &
GRANITE, INC., a Florida Corporation;EAST
COAST CONTRACTORS SUPPLY, INC., a
Florida corporation;FERGUSON ENTERPRISES,
INC.,
a
Florida
corporation; FINE
LINE
ELECTRIC, INC.; a Florida corporation;FLOOD
PANEL, LLC, a Florida limited liability
company;
HOLLYWOOD
STONE,
INC.,
a
Florida
corporation;
J.L.K. CAULKING AND COATINGS
COMPANY, a Florida corporation;LUSHLIFE,
LLC, a Florida limited liability
company; NEW
DOOR
INSTALLATION
CO.,
a
Florida
corporation; NEXT
DOOR DISTRIBUTION
COMPANY, an inactive Florida corporation;R&L
PAINTING, INC., a Florida corporation;ROSEN
MATERIALS, LLC, a Florida limited liability
company;
SECURITY
INNOVATIVE
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/25/2021 04:37:59 PM.****
SOLUTIONS,
INC.;
a
Florida
corporation;
SOUTHERN COAST ENTERPRISES, INC.; a
Florida corporation;SOUTH DADE LIGHTING
INC., a Florida corporation;SOUTHERN FIRE
CONTROL, INC., a Florida corporation;TEKTON
CONSTRUCTION, CORP., a Florida corporation;
and
ZARRELLA CONSTRUCTION, INC. a
Florida corporation;
Defendants,
i
PMG DRIFTWOOD, LLC, a Florida limited
liability
company,
Plaintiff.
VS.
SAGE
BEACH
CONDOMINIUM
ASSOCIATION, INC., a Florida not-for-profit
corporation,
Defendant.
i
DEFENDANTS, PMG DRIFTWOOD, LLC'S AND GLENEWINKEL CONSTRUCTION
COMPANY, LLC'S EXPERT WITNESS DISCLOSURE
Defendants, PMG Driftwood, LLC ("PMG") and GLENEWINKEL CONSTRUCTION
COMPANY, LLC ("GCC"), by and throughthe undersignedcounsel,pursuant to the Court's Case
Management Order dated August 5,2021 and subsequent Agreed Order on Plaintiff's Motion for
Extension of Time to Serve Expert Disclosure dated August 20, 2021, hereby files their Expert
Witness Disclosure and states as follows:
1.
Jose A. Vargas, PE
Mc Consultants,Inc.
Altamonte SpringsOffice
600 Northlake Blvd.,#100
Altamonte Springs,FL 32701
2
Mr. Vargas is a professionalengineerand his background, training,and experienceare
described in his CV, which is attached hereto as Exhibit "A." Mr. Vargas is expectedto testify
regardingthe claims being made by Plaintiff againstPMG and GCC. Mr. Vargas is expected to
providetestimonyto respond to Plaintiff's experts and/or other parties'
experts regardingalleged
construction defects or deficiencies. He is expected to relyon his training,education, experience,
industrystandards and methods, scientific data,review ofrelevant documentation includingexpert
reports, expert opinions,testimony or statements of any party or non-party in this case in
formulatinghis opinion.
2.
Anthony Millward, P.E., Leed AP
Mc Consultants,Inc.
Altamonte SpringsOffice
600 Northlake Blvd.,#100
Altamonte Springs,FL 32701
Mr. Millward is professionalengineerand his background,training,and experienceare
described in his CV, which is attached hereto as Exhibit "B." Mr. Millward is expected to testify
regardingclaims made by Plaintiff againstPMG and GCC. He is expected to providetestimony
regardthe allegeddeficiencies,
liability
and damages related to the designand construction ofthe
mechanical, electrical,
plumbing, HVAC, and life safetysystems ofthe Project.He is expected to
relyon his training,
education,experience,industrystandards and methods, scientific data,review
of relevant documentation includingexpert reports, expert opinions,testimony or statements of
any party or non-party in this case in formulatinghis opinion.
3
Don Rataj
Mc Consultants,Inc.
Altamonte SpringsOffice
600 Northlake Blvd., #100
Altamonte Springs,FL 32701
3
Mr. Ratajis an architect and his background, training,and experienceare described in his
CV, which is attached hereto as Exhibit "C." Mr. Rataj is expected to testifyregardingclaims
made by Plaintiff againstPMG and GCC. He is expected to provide testimony regardingthe
architectural standard of care and to providetestimony to respond to Plaintiff's experts and/or
other parties'experts regardingallegeddsign defects or deficiencies. Mr. Ratajis expected to rely
on his training,education,experience,industrystandards and methods, scientific data,review of
relevant documentation includingexpert reports, expert opinions,testimony or statements of any
party or non-party in this case in formulatinghis opinion.
4.
Charles Braznell
Mc Consultants,Inc.
Altamonte Springs Office
600 Northlake Blvd., #100
Altamonte Springs,FL 32701
Mr. Braznell is a certified generalcontractor and his background,training,
and experience
are described in his CV, which is attached hereto as Exhibit "D." Mr. Braznell is expected to
testifyregardingclaims made by Plaintiff againstPMG and GCC. He is expected to provide
testimonyto respond the opinionsofPlaintiff's experts and/or any other parties'
experts regarding
the allegeddefects at the Project,the generalcontractor's standard of care, the appropriatemethod
and cost of repair,and delays. Mr. Braznell is expected to relyupon his training,education,
experience,industrystandards and methods, scientific data,review ofrelevant documentation, and
the testimonyor statements of any party or non-party in this case in formulatinghis opinion.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANKI
4
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY a true and correct copy ofthe foregoingwas served via electronic
mail pursuant to Florida Rule of Judicial Administration 2.516 using Florida Court's E-Filing
Portal to all counsel on this 251:th day of October 2021.
Respectfullysubmitted,
BAUM-ANN, GANT & KEELEY, P.A.
Attorney for Defendants,
PMG DRIFTWOOD, LLC, and GLENEWINKEL
CONSTRUCTION COMPANY, LLC
1401 East Broward Boulevard, Suite 200
Fort Lauderdale, FL 33301
(954)440-4611 phone
/s/ Elizabeth M. White
Gary F. Baumann, Esq.
FL Bar No.. 089052
GBaumann@baumannlegal.com
Elizabeth M. White, Esq.
FLBar No.. 100435
EWhite@baumannlegal.com
5
EXIIIBIT "A99
-C
EXPERIENCE AND INNOVATION SERVING CLIENTS NATIONWIDE
CONSULTANTS INC.
PROFESSIONAL CURRICULUM VITAE
OF
JOSE A. VARGAS, P.E.
Position:
Expert - Structural Engineer
Licenses:
Florida Professional Engineer License 54645
Florida Special (Threshold) Inspector License SI #7017331
Georgia Professional Engineer License PE036861
Pennsylvania Professional Engineer License PE080337
New Jersey Professional Engineer License 24GE05080000
North Carolina Professional Engineer License 041013
South Carolina Professional Engineer License 31262
Education:
Bachelor of Science, Civil Engineering, November 1992
UNPHU, Santo Domingo, Dominican Republic
Master of Science, Civil Engineering, May 1997
The Universityof Texas at Austin
Professional
Certifications:
Scaffold OSHA Subpart L Safety Training: Suspended
Platform User Awareness
Experience:
2014-Present: Expert - Structural Engineer
MC Consultants, Inc.
Responsibilities include forensic investigation,document
analysis, development of repair recommendations, delay
analysis, contract disputes, building code and materials
research, standard of care, and expert witness testimony.
Expertise in litigation
support involvingstructural
construction defects.
2010-Present: Principal
Alpha Services, LLC, Orlando, Florida
Structural analysis and design, special (threshold)inspection
services.
Relevant Projects:
Embry-Riddle Aeronautical
-
University
Jim Henderson
Administration and Welcome Center. This 35,000 square
feet facilityis located in Daytona, Florida. It includes a large
multi-purpose assembly area, 3-story atrium space,
Corporate Office - 2055 Corte del Nogal - Carlsbad, CA 92011 - Tel: (760) 930-9966 - Fax: (760) 930-9974
www.mcconsultants.com
Altamonte Springs Office - 600 Northlake Blvd, #100 - Altamonte Springs, FL 32701 - Tel: (321) 972-
0787 - Fax: (321) 972-0791
-C
CONSULTANTS INC.
Experience
(Continued):
administration office spaces and the President's office. 40-
foot-long cantilevers, sloping and curved roofs define its
elegant geometry.
Baha Mar, Nassau, The Bahamas - $3.5 Billion-dollar luxury
resort, casino and convention center, under construction
(estimated completion by end of 2014). External adviser,
team leader for code enforcement agency for structural
reviews and inspections.
Seminole Hard Rock Caf@ Expansion, Tampa - Steel
Connection design
University of South Florida Sun Dome Arena Renovation -
Steel Connection design.
University of Florida Frank Stronach Plant Science Center
(IFAS
-
Citra)
Structural Design of Pavilion and Exhibition
Area.
South Georgia Medical Center, 96-Bed Patient Tower -
Structural Design Review.
Wellington Regional Medical Center- Structural Design
Review
Peabody Hotel Tower 2 - Wall at Low Roof Exhaust Area.
Activity Building at WFW, Osceola County, Florida -
Threshold Inspections
Drury Inn Suites, Orlando, Florida - Threshold Inspections
1997 - 2010: Principal
Walter P. Moore and Associates, Orlando, Florida
Project Manager for structural analysis and design of high-
rise buildings,convention centers, hotels, hospitals,
stadiums, airports,educational facilities and other structures.
Relevant Projects:
University of Central Florida College of Medicine - This four-
story, 168,000-square-feet buildingis a state-of-the-art
medical instructional building.It is located on the Lake Nona
Health Sciences Campus, in Orlando, Florida. It includes the
-C
CONSULTANTS INC.
Experience
(Continued):
medical school, laboratories, lecture halls and medical
library.The cost is approximately $54 million. It opened in
August, 2010. The structural framing consists of post-
tensioned beams and pan-joistsystem. 60-foot long post-
tensioned transfer girders allow for the creation of large
lecture halls without columns. A beautiful 30-foot tall clock
tower extends above the roof.
The Plaza - 1.3 million square feet, mixed-use facilityin
downtown Orlando, Florida. It includes two office towers (16
and 21 stories)that sit on a 9-story parking garage (1,600
cars) that covers two cityblocks. Retail spaces are on the
first floor,while 12 movie theaters occupy part of level 2. A
30-story residential tower also sits on the garage podium.
The structural framing consists of cast-in-placepost-
tensioned beams and mild-reinforced slab, shear walls, and
foundation on 78-foot piles.One of the challenges was not to
affect the adjacent existing structures with brick fagade.
Completed in 2007.
Florida Hospital Altamonte Patients Tower, Altamonte
Springs, Florida - This expansion included a 6-story patient
tower of 190,000 square feet,26,000 square feet of new
emergency department and intensive-care unit space,
28,000 square feet of surgery rooms, and the expansion of
the central energy plant.Expansion cost was about $58
million. The structural systems used included concrete
frames and pan joistswith foundation on pilesfor the tower,
and composite steel framing for the other structures.
Completed in 2007.
University of Phoenix NFL Stadium, Tempe, Arizona - Home
to the NFL Arizona Cardinals. Retractable roof stadium (and
also retractable playing surface).Worked on detailingof the
roof connections and in-house software to design and detail
connections, includingthe two main 700-foot long trusses of
Ienticular profile.Construction cost $455 million and was
opened in August, 2006.
Orange County Convention Center Phase V, Orlando,
Florida - This expansion of 3 million square feet made this
the second largestconvention center in the United States.
180-foot long steel trusses help create over a million square
feet of unobstructed exhibit space. Steel framing over the
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CONSULTANTS INC.
Experience
(Continued):
north and south entrances create an elegant, unique feature
for the facility.
Emergency and service tunnels were
provided. Cost $748 million. Completed in 2003.
Dvnetech Centre - 30-story tower in downtown Orlando,
Florida. This 614,000 square foot, mixed-used facility
consists of retail space on the first floor,9 floors of parking, 7
floors of office space, 12 floors of apartments with roof-top
swimming pool and sundeck. The structural system uses
cast-in-placepost-tensioned flat plateslab, shear wall core,
sloping columns between levels 13 and 16, and foundation
on augercast piles.
Orlando International
-
Airport
Airside 2, Orlando, Florida -
318,870 square feet airside facility,
with a central hub linked
to the terminal monorail system and two wings that
accommodate 16 jetgates. Structural system consists of
steel framing and composite steel floors. Cost was $70
million. Itwas completed in September, 2000.
Universal Studios Citvwalk, Orlando, Florida - CityWalk is
the gateway for Universal Studios theme parks and resorts.
It includes theme restaurants, 20-screen Cineplex and
shops. Construction of this 600,000 square feet facilitycost
about $200 million.
University of Miami Interdisciplinary Laboratory Building,
Miami, Florida - This research facility
consists of 9 floors of
laboratory space, 2 floors of mechanical penthouse starting
on the tenth floor. The cost was $55 million and was
completed in 2009. Structural framing consisted of pan-
formed joistsand slabs, shear walls and augercast pile
foundation.
Seminole County Courthouse, Florida - Five-story,211,000
square-foot structure. It has an elegant three-tier spire that
cantilevers 50 feet above the roof. Structural framing
consists of composite steel floors and braced frames. The
prisoner cells are in the basement, which is 11 feet below
the water table. Construction cost $30 million and was
completed in 2004.
Denver Broncos NFL Stadium, Denver, Colorado
Eola Park South- Condominium Building, Orlando, Florida
Maitland Promenade Opus Office Building, Maitland, Florida
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CONSULTANTS INC.
Experience
(Continued):
Orange County Convention Center West Entrance
Expansion
Or ando International Airport - South Terminal Complex,
Or ando, Florida
Disney New York Street, Orlando, Florida
2008 - 2009: Adjunct Professor
University of Central Florida, Orlando, Florida
Adjunct Professor in the Civil,Environmental, and
Construction Engineering Department
Published
Materials:
"A Designer's View of Fly Ash Concrete." Concrete
International. February, 2007.
Seminars &
Presentations
Given:
Instructor - Professional Engineer's Exam Review Seminar
(variousstates).
Past/Present
Affiliations:
President - American Concrete Institute,Central Florida
Chapter.
EXIIIBIT "B99
-C
EXPERIENCE AND INNOVATION SERVING CLIENTS NATIONWIDE
CONSULTANTS INC.
PROFESSIONAL CURRICULUM VITAE
OF
ANTHONY MILLWARD, P.E., LEED AP
Education:
BS/Mechanical Engineering
University of Florida/1974
Registration:
Professional Engineer - Mechanical & Electrical
Alabama No. 39094
Arizona No. 59179
Arkansas No.18003
Ca ifornia (Electrical)No. 20534
Ca ifornia (Mechanical) No. 36624
Florida No. 20830
Illinois No. 062.070009
Iowa No. P25195
Kansas No. PE26214
Kentucky No. 33583
Louisiana No. PE.0042541
Maryland No. 54002
Massachusetts No. 55194
MississippiNo. 30901
Nevada No. 22528
New Jersey No. 24GE05561300
New York No. 094080
North Carolina No. 9218
Oklahoma No. 31940
Oregon No. 86386 PE
Pennsylvania No. PE082060
Rhode Island No. 13434
South Carolina No. 31412
Tennessee No. 120931
Texas No. 129237
Virginia No. 0402053242
Washington No. 50854
Washington, D.C. (Electrical)
No. PE 907567
Washington, D.C. (Mechanical) No. PE 907566
Wisconsin, No. 47040-6
Wyoming, No. PE 17895
LEED Accredited Professional
National Council of Examiners for Engineering and
Surveying License (NCEES) No. 45232
Corporate Office - 2055 Corte del Nogal - Carlsbad, CA 92011 - Tel: (760) 930-9966 - Fax: (760) 930-9974
www.mcconsultants.com
Altamonte Springs Office - 600 Northlake Blvd, #100 - Altamonte Springs, FL 32701 - Tel: (321) 972-
0787 - Fax: (321) 972-0791
C
CONSULTANTS INC.
Professional
Affiliations:
American Society of Mechanical Engineers
National Fire Protection Association
American Society of Plumbing Engineers
American Society of Heating, Refrigeration
and Air ConditioningEngineers
Institute of Electrical and Electronics Engineers (IEEE)
IlluminatingEngineering Society (IES)
Certifications:
OSHA 29 CFR 1910.146 - Confined Space Entry
Years Of
Experience:
44 Years
Experience
Summary:
For over 34 years managed a successful engineering
company specializingin design of mechanical,
electrical and plumbing systems. Experience includes
the areas of HVAC, plumbing, fire protection,power,
lightingand communications. Designed mechanical
and electrical systems for industrial plants,theme park
rides,hospitals,offices,education and training
facilities,
hotels, apartments, restaurants, high rise
housing, churches, retail stores and computer rooms.
Air conditioning designs range in size from 5 tons
through 2,100 Tons and include central chillers,DX
coils,VAV and constant volume applications.
Designed computer chilled water-coolingsystems,
industrial ventilation systems for dust and fume
removal and process steam hydraulic,compressed air,
and chilled water piping.Designed plumbing and fire
protectionsystems for buildingsranging in size from
8,000 square feet through 237,000 square feet and up
to seven floors in height.Fire protectiondesigns
include wet-pipe, dry-pipe,Halon, CO2, AFFF and dry
chemical systems. Designed building electrical power
systems up to 14,250 KVA, signal and
communications systems, lighting,
lightningprotection,
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CONSULTANTS INC.
Experience
Summary
(Continued):
fire detection and alarm systems, medium voltage
utility
power, emergency power generating systems
and central energy management systems. Several
designs have included buildings that qualified for
LEED certification. Mechanical and electrical project
management experience includes over a hundred
projectsranging in size from $1.0 million to over
$300.0 million.
Representative
Projects:
Engineer of Record providing primary design decisions
and supervision for design development of
construction documents for the following systems and
projects.
Engineer of Record for Electrical Power, Lightingand
Communications, HVAC, Plumbing, and Fire
Protection Systems for Pandora Land Addition at Walt
Disney World's Animal Kingdom., Lake Buena Vista,
Florida. This projectinvolved extensive development of
a 5 Acre site,a new 205,200 square foot ride facility,
a
19,500 square foot restaurant, a 7,000 square foot
retail shop and 6,000 square feet of restroom facilities.
Design included a central energy plant providing 2,100
Tons of chilled water refrigeration,14,200 KVA utility
power center and 9.360 MBTU of heating water. Total
projectcost $320.0 million. Total projectduration of
four years from beginning of design to completion of
construction.
Electrical Power, Lighting,Communications, HVAC,
Plumbing and Fire Protection Systems for Walt
Disney's Magic Kingdom Cosmic Ray's Restaurant
Restroom & Seating Expansion, 12,000 sq. ft.
Electrical Power, Lighting,Communications, HVAC
and Plumbing for Crown Linen Laundry Plant,52,000
sq. ft.
HVAC and Plumbing for Disney Hollywood Studios
Fireworks Launch Site and Control Building, 14 Acre
Site,250 sq. ft.,Building.
Electrical Power, Lighting,Communications, HVAC
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CONSULTANTS INC.
Representative
Projects
(Continued):
and Plumbing Systems for Option Care
Pharmaceutical Clean Room Facilityin Gainesville,
Florida,7,200 sq. ft.,and Portland, Oregon, 13,100 sq.
ft. Electrical Power, Lighting,Communications, HVAC
and Plumbing Systems for Pleasant Hill Voluntary Pre-
Kindergarten Facility,
18,400 sq. ft.
Roadway Lightingfor Walt Disney World's Center
Drive Realignment, 0.7 Mi.
Mechanical and Electrical Systems Evaluation for
Disney's Yacht & Beach Resort, 6 Acre Water Park
Pool Facilities
Electrical,HVAC, Plumbing, and Fire Protection
Systems for Hanson Pipe Corporation,Computerized
Concrete Pipe Manufacturing Plant, Winter Haven,
Florida,170,000 sq. ft.,7500 KVA, $20.0 million.
Buildingand Site Electrical,HVAC, Plumbing, and Fire
Protection Systems for Defense LogisticsAgency
Distribution Center, Tinker Air Force Base, Oklahoma,
170,000 sq. ft.,1500 KVA, $32.0 million.
Electrical Power, Lightingand Communications
Systems for Full Sail Live Theater, Winter Park,
Florida,22,000 sq. ft.,1,500 KVA, $4.8 million.
HVAC, Plumbing, Fire Protection and Electrical
Systems for Electronics Training 'A' School at Naval
Training Center, Orlando, Florida, 150,000 sq. ft.,800
tons, 2500 KVA, $13.1 million.
HVAC, Plumbing, Electrical Power, and Lighting,
IncludingRide Power Distribution Center for Magic
Carpets of Aladdin Ride Control Console at Walt
Disney World's Magic Kingdom Theme Park, Lake
Buena Vista, Florida,$0.5 million
HVAC, Plumbing, Fire Protection and Electrical
Systems for MGM Studio's Back Stage Tour Preshow
and Tramload, Lake Buena Vista, Florida,$1.4 million.
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CONSULTANTS INC.
Representative
Projects
(Continued):
Electrical and Fire Protection Systems for Renovations
to CrystalPalace Restaurant at Walt Disney World's
Magic Kingdom, Lake Buena Vista, Florida.,$1.25
million.
HVAC and Electrical Systems for Air Conditioning
Replacements at Universal Studios ET Ride
Merchandise Shop, Orlando, Florida,4,000 sq. ft.,50
tons, 50 KVA, $40 thousand.
HVAC and Electrical Systems for Renovations to the
Mel's Diner Kitchen at Universal Studios Theme Park,
Orlando, Florida,3,000 sq. ft.,40 tons, 60 KVA, $100
thousand.
Plumbing and Electrical Systems of Marine Life
Support Equipment for Lobby Fountain and Lagoon at
Walt Disney World Polynesian Resort, Lake Buena
Vista, Florida,$100 thousand.
HVAC, Plumbing, Fire Protection, Electrical Power,
Lighting and Communication Systems for The Lion
King Theater in the Mickey-Minnie Camp at Walt
Disney World's Animal Kingdom Theme Park, Lake
Buena Vista, Florida,$12 million.
HVAC, Plumbing, Fire Protection, Electrical Power,
Lighting and Communication Systems for The
Pocahontas Show Stage and Animal Holding Facilityin
the Mickey-Minnie Camp at Walt Disney World's
Animal Kingdom Theme Park, Lake Buena Vista,
Florida,$4 million.
HVAC, Plumbing, Fire Protection, Electrical Power,
Lightingand Communication Systems for Restroom
Facilities,Character Greeting Structures, and All
Support Structures in the Mickey-Minnie Camp at Walt
Disney World's Animal Kingdom Theme Park, Lake
Buena Vista, Florida,$3 million.
HVAC, Plumbing, Electrical Power, and Lightingfor a New
Fellowship Hall at Emmanuel Church of The Nazarene,
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CONSULTANTS INC.
Representative
Projects
(Continued):
4,600 sq. ft.
HVAC, Plumbing, Electrical Power, and Lightingfor
Additions and Renovations at Mandarin United
Methodist Church, 10,000 sq. ft.
HVAC, Plumbing, Electrical Power, and Lightingfor a New
Worship Sanctuary at Sopchoppy BaptistChurch,
6,800 sq. ft.
HVAC, Plumbing, Electrical Power, and Lighting for New
Three BuildingBirth Education & Training Assistance
(BETA) Facility,
14,900 sq. ft.
HVAC, Plumbing, Fire Protection, and Compressed Air
for Facilities and Site of the Dino Rama Expansion to
the Dinoland Area at Walt Disney World's Animal
Kingdom Theme Park, Lake Buena Vista, Florida,$4
million.
HVAC, Plumbing, Fire Protection, Electrical Power,
Lighting and Communication Systems for Siemens
Corporation VIP Center at Spaceship Earth in Walt
Disney World's EPCOT Theme Park, Lake Buena
Vista, Florida.
HVAC, Plumbing, Fire Protection, Electrical Power,
and LightingSystems for Air Handler Replacements at
GM Test Track in Walt Disney World's EPCOT Theme
Park, Lake Buena Vista, Florida,$1.1 million.
HVAC, Plumbing, Fire Protection, Electrical Power,
and Lighting Systems for Air Handler Replacements at
the China Pavilion in Walt Disney World's EPCOT
Theme Park, Lake Buena Vista, Florida,$0.6 million.
HVAC, Electrical Power, and Lightingfor Give Kids the
World Pirate Ship Stage and Control Booth, Go Cart
Track and Game Room.
Electrical Systems for Renovations at Twenty-two of
Walt Disney World Cast Commissary's, Lake Buena
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CONSULTANTS INC.
Representative
Projects
(Continued):
Vista, Florida,$1.25 million.
HVAC, Plumbing, Fire Protection, and Electrical
Systems for Design of Mickey's Starland at Walt
Disney World's Magic Kingdom Theme Park, Lake
Buena Vista, Florida,$0.60 million.
HVAC and Plumbing Systems for Enlisted Dormitories,
Seymour Johnson Air Force Base, North Carolina,
52,000 sq. ft.,124 Tons, $10.4 million.
Electrical Power, Lightingand Communications
Systems for Full Sail Studio 'D',Recording Studio and
Gaming Design School, Winter Park, Florida, 10,400
sq. ft.,350 KVA, $2.3 million.
Heating Water, Steam, Plumbing, Fire Protection and
Electrical Systems for New Gas Fired Boilers at Walt
Disney World Polynesian Resort, Lake Buena Vista,
Florida,47,000 MBTU, $1.5 million.
FeasibilityStudy for New Gas Fired Boilers at Walt
Disney World Contemporary Resort, Lake Buena
Vista, Florida,40,000 MBTU, $1.8 million
HVAC and Electrical Systems for Air Conditioning
Renovations at Walt Disney World Central Laundry
Facility,Lake Buena Vista, Florida, 30,000 sq. ft.,250
tons, 400 KVA, $0.25 million.
HVAC, Plumbing and Fire Protection for the
Tomorrowland Theater at Walt Disney World's Magic
Kingdom Theme Park, Lake Buena Vista, Florida,
21,000 sq. ft.,$1.5 million.
Rewiring Design for Electrical Distribution at Walt
Disney World Grand Floridian Convention Center,
Lake Buena Vista, Florida, 16,000 sq. ft.,
$140 thousand.
Electrical,HVAC, Plumbing, and Fire Protection
Systems for Baldwin Place Condominium Tower,
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CONSULTANTS INC.
Representative
Projects
(Continued):
Orlando, Florida,77,000 sq. ft.,750 KVA, $12.0 million.
HVAC, Plumbing, Fire Protection and Electrical
Systems for Venice Golf & Country Club &
Restaurant, Venice, Florida, 19,000 sq. ft.,$2 million.
Buildingand Site Electrical,HVAC, Plumbing, and Fire
Protection Systems for Defense LogisticsAgency
Distribution Center, Warner Robins Air Force Base,
Georgia, 168,000 sq. ft.,1500 KVA, $28.0 million.
Electrical Power, Lighting,Audio, Communications,
Gas, Water and Sanitaryfor the Adventureland
Moroccan Villageat Walt Disney World's Magic
Kingdom Theme Park, Lake Buena Vista, Florida,$2.5
million.
Site Electrical Power, Lighting,Audio,
Communications, Gas, Water, Sanitary,and
Compressed Air for Magic Carpets of Aladdin Ride at
Walt Disney World's Magic Kingdom Theme Park,
Lake Buena Vista, Florida,$2 million.
Electrical Power, Lightingand Communications
Systems for Full Sail Data Center, Winter Park, Florida,
4,000 sq. ft.,750 KVA, $1.0 million.
Site Lighting and Electrical Power for Full Sail Live
Entry Park, Winter Park, Florida, 1 + Acre, 50 KVA,
$1.0 million.
Recovery Response QualityAssurance Support for
Army Corps of Engineers Task Force Addressing the
2011 Alabama Spring Tornado Event, Tuscaloosa,
Alabama.
Site Electrical Power and Lightingfor the New
Magnolia Avenue and Eustis Street Downtown
Streetscape, Eustis, Florida,4 Blocks, $200 thousand.
Site Electrical Power, Audio, Communications, and
Lightingfor the Mickey-Minnie Camp at Walt Disney
C
CONSULTANTS INC.
Representative
Projects
(Continued):
World's Animal Kingdom Theme Park, Lake Buena
Vista, Florida,10 Acres, $7 million.
Disaster Response Audits and Design Support for
Hurricane Damage at the U. S. Government Radar
Surveillance Installation near Homestead, Florida.
Disaster Response Audits and Design Support for
Hurricane Damage at the U. S. Naval Observatory
Time Service Administration Station (NOTSAS) Near
Homestead, Florida.
Disaster Response Audits and Design Support for
Hurricane Damage at the U. S. Naval Base in
Charleston, South Carolina.
HVAC, Plumbing and Electrical Systems for
Renovations to Gateway Inn Restaurant and Lounge,
Orlando, Florida,13,300 sq. ft.,$0.34 million.
Heating Water and Chilled Water Condition Survey for
all Above and Below Ground Air Conditioning Piping
Systems at Walt Disney World Polynesian Resort,
Lake Buena Vista, Florida.
Mechanical, Plumbing and Electrical Systems for
Water Treatment and Storm Water Transfer Pumping
System Serving the Central Lagoon in Universal
Studios Theme Park, Orlando, Florida,2 Acres, 60
KVA, $120 thousand.
Mechanical and Plumbing Systems for Modifications to
the Spiderman Ride Fog System at Universal Studios
Theme Park, Orlando, Florida, 10,000 sq. ft.,$30
thousand.
EXIIIBIT "C99
-C
EXPERIENCE AND INNOVATION SERVING CLIENTS NATIONWIDE
CONSULTANTS INC.
PROFESSIONAL CURRICULUM VITAE
OF
DONALD J. RATAJ, AIA, NCARB
Position:
Expert - Architect
Licenses:
Alabama Architect License 7705 (Active)
Arizona Architect License 44241 (Inactive)
Colorado Architect License ARC.00400755 (Inactive)
Florida Architect License AR93653 (Active)
Georgia Architect License RA011215 (Active)
Illinois Architect License 001011897 (Inactive)
Indiana Architect License AR19800093 (Inactive)
Iowa Architect License 03910 (Active)
Kentucky Architect License 6183 (Inactive)
Louisiana Architect License 8524 (Active)
Michigan Architect License 1301054696 (Inactive)
Minnesota Architect License 44813 (Inactive)
MississippiArchitect License 4194 (Inactive)
Missouri Architect License 004135 (Active)
New Hampshire License 04363 (Active)
New Jersey Architect License 21 AI00930700 (Inactive)
New York Architect License (Pending)
North Carolina Architect License 10579 (Inactive)
Ohio Architect License ARC.0413641 (Active)
Oklahoma Architect License A4888 (Inactive)
Pennsylvania Architect License RA404270 (Inactive)
South Carolina Architect License 9982 (Active)
Tennessee Architect License 103037 (Inactive)
Texas Architect License 19447 (Active)
VirginiaArchitect License 0401017204 (Active)
Wisconsin Architect License 10337 (Inactive)
American Institute of Architects (AIA) No. 38405117
National Council of Architectural RegistrationBoards
(NCARB) Certification (1985), Record No. 37944, Certificate
No. 32406
Education:
Bache or of Environmental Design, University of Kansas,
Schoo of Architecture & Urban Design (1976)
AIA/NCARB current continuing education for multi-state
licenses, Florida State Advanced ASCE 7
Corporate Office - 2055 Corte del Nogal - Carlsbad, CA 92011 - Tel: (760) 930-9966 - Fax: (760) 930-9974
www.mcconsultants.com
Altamonte Springs Office - 600 Northlake Blvd, #100 - Altamonte Springs, FL 32701 - Tel: (321) 972-
0787 - Fax: (321) 972-0791
-C
CONSULTANTS INC.
Experience:
2014-Present: Expert - Architect, MC Consultants, Inc.
Responsibilitiesinclude forensic investigation,failure analysis,
document review, development of repairrecommendations,
evaluatingdesign and construction contract disputes,building
code and materials research, standard of care, ADA compliance,
water damage and mold, and expert witness testimony.
2013- Present: Don Rataj Architect & Architectural Expert
Witness
Provided legalexpert discovery and testimony on items related
to: Architectural Design, ADA compliance, AIA documents and
contracts, building codes, life safety, movie theater design, and
building construction related issues.
2000-2012: CEO, Rataj-Krueger Architects, Inc.
1992: Incorporated Rataj Architects, Inc.
1985: Established and Founded - Rataj Architects
Strategicallyplanned and designed an open office format for
the development of a creative design staff of architects and
interior designers, mentored by hands-on experience.
The buildingdesign completed projects completed from 1985
to 2012 can be viewed on the Architectural firm's website:
-.rkai.net.
Public Speaking
Presentations:
Speaker at the President's Forum conference on "Making More
Green by Going Green", 2009.
Speaker at ShoWest Theater convention on ADA movie theater
seating compliance, 2005.
Awards:
Received "Gold Medal" Honors from the Building of America
Award for the completed Campbell Montessori School, St.
Charles, MO, 2010.
Awarded Best Places to Work for People Development by St.
Louis Business Journal, 2003 & 2004.
Received award by Masonry Institute for Excellence in Masonry
Design, 2003.
-C
CONSULTANTS INC.
Affiliations:
The American Institute of Architects (AIA)
National Council of Architectural Registration Boards
(NCARB)
Member of American Association of Arbitrations,Past Arbitrator
Member and Speaker for Green Connected/Sustainable Design
EXIIIBIT "D99
-C
EXPERIENCE AND INNOVATION SERVING CLIENTS NATIONWIDE
CONSULTANTS INC.
PROFESSIONAL CURRICULUM VITAE
OF
CHARLES BRAZNELL
Position:
-
Expert
General Contractor
Licenses:
F orida State General Contractors License - CGC 055924
F orida State BuildingContractors License - CBC 047693
Certifications:
AIA CE FI Admin Code (FBC)
AIA CE Green Building Design
AIA CE Metal Joists & Decking
AIA CE BuildingFenestration
AIA CE Coatings & Sealants
Certified Estimator, Construction Estimation School
Certified FAA Airfield Access
Certified Federal Bureau of Prisons
Certified AHCA FL Healthcare
OSHA Certified
PM Certification,Turner School of Management
Education:
Bachelor of Science, Engineering
Florida International University
Professional
Summary:
Over thirtyyears experience managing commercial and
institutional construction projectsfor Federal, State, Municipal
and Private clients. Performance includes estimating,
purchasing, supervision,scheduling, management and claims
analysisof multi-family,
hospital,airport,
military,
manufacturing and historic restoration projectsto $150M.
Experienced in providing Owner/Contractor Representation
and Expert Witness Services for the resolution of performance
and claims issues.
Experience:
2021-Present: Expert - General Contractor
MC Consultants, Inc.
Responsibilities include forensic investigation,document
analysis, development of repair recommendations, contract
disputes, buildingcode and materials research, standard of
care, and expert witness testimony.
Corporate Office - 2055 Corte del Nogal - Carlsbad, CA 92011 - Tel: (760) 930-9966 - Fax: (760) 930-9974
www.mcconsultants.com
Altamonte Springs Office - 600 Northlake Blvd, #100 - Altamonte Springs, FL 32701 - Tel: (321) 972-
0787 - Fax: (321) 972-0791
-C
CONSULTANTS INC.
Project
Experience:
Institutional/Healthcare & Medical
NutraMedix (FDA); Clean Room
Animal Kennel Rooms; VCA of America
Forensic Lab, FWC; Grassey Waters
Metro ogy Lab; Multi Parts Supply
.
Metro ogy Laboratory;Florida Metrology
Quarantine Barn; Black Swan Stables
Frac Lab; NABI Biopharmaceuticals
.
Bascom Palmer Facility;Universityof Miami
HVAC/Chiller Replacement; FAU
Lewis Radiography Building;PBCC
B2 Main Lab; NABI Biopharmaceutica s
Clean Room; NABI Biopharmaceutica s
Freezer; NABI Biopharmaceuticals
Research Building;MIA Children's Hospital
.
Entrance Lobby; Boca Medical Center
Research Building;VA Medical Center MIA
POB Building;Miami Children's Hospital
MRI Building;Miami Children's Hospital
FOB Building;Miami Children's Hospital
,
Morgue; Miami Children's Hospital
Institutional/Aviation facilities
ADA Bathrooms; Ft Safety International
Bl C assrooms; Ft Safety Internationa
B2 C assrooms; Ft Safety Internationa
ADA Bathrooms MIA Airport
Terminal "E"/Greeter Lobby, MIA
.
Cargo Warehouse No. 2129, MIA
Institutional/Parking facilities
Anchor Place Garage; St. Moritz Hotel
.
Garage I;Miami Children's Hospital
Garage Il;Miami Children's Hospital
Commercial/Banking Facilities
.
Operations Center; Southeast Mortgage
Wachovia Bank; Stuart
Southeast Bank; Various Locations
-C
CONSULTANTS INC.
Project
Experience
(Continued):
Commercial/Auto Dealerships
Williamson Cadillac,Dade and
Saturn of Dadeland, Dade and
Commercial/Historic Restoration
.
Deering Estate; Metro-Dade County
Hilton Ocean P aza; Hilton Hotels
.
Coral Gables E ementary School
Pigeon Key Restorations; FL DOT
Bank Restoration; Southeast Bank
Institutional/Educational & Worship
Schoo Bui dout; Pivot Charter School
Schoo Bui dout; Renaissance Charter
Hendersen Building;FL Atlantic University
Allied Health Building,PBCC
o
Duncan Theater, PB Community College
Math & Reading Lab, PBCC
Bui ding 3000 Miami Dade Community College
Bui ding 6000 Renovations, MDCC
.
Sanctuary; Berean BaptistChurch
.
Classrooms; United Methodist Church
Institutional/Government facilities
Generator Building.;Cityof W Palm Beach
Fuel Storage Yard; City of WPB
Offices;Regional Sewer Plant,WPB
Koala Exhibit Building;Palm Beach Zoo
Cemetery; VA Administration WPB
BK Foundation; VA Administration MIA
Dormitory; MIA MCC Fed Bur. Prisons
Bui ding 2323, Homestead AF Base
Bui ding 717, Homestead AF Base
Commercial/Multifamily & Hotel
Hotel Resort; Costa Hollywood Resort
.
Common Area Buildings.;Delray Estuary
Apartment Building.;Roan Lane Apartments
FlaglerSt. Apartments; Parkland Companies
Somerville Apartments; Camillus House
Pll & PIll Keys Apartments; Brannon Group
-C
CONSULTANTS INC.
Project
Experience
(Continued):
.
Flex Warehouses; Jupiter Trade Center
.
Monument Sign; JupiterTrade Center
o
Warehouse Park; Haverhill Bus. Park
.
Showroom Warehouse; Palmetto Palms
o
Warehouse; MIA Children's Hospital
Packing House; Far South Growers
Commercial/Retail/Tenant Buildout
Office Bui dout; Rohl Networks
Office Bui dout; SoHo Myriad Atlanta
o
Beacon Center, Reiker Duley
Office Buildout; Centurium Inc
Restaurant; Ruby Tuesday
.
Tenant Improvements; Salon 54
.
Tenant Improvements; Simply Flowers
.
Tenant Improvements; Lovable Puppie
Office Bui dout; Power Concepts
Office Bui dout; BCI International
o
Renovations; Riviera Country Club
Seminars/
Lectures:
FL HRS Safety/Building,1987 - 1991
Florida Construction Law, 1988
Affiliations:
o
Associated General Contractors
Associated Building Contractors
e
Building Trades Association
Jupiter First Children Ministries
Limestone Creek PTO
Jupiter Middle PTO
Jupiter/Tequesta Athletic Association