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  • Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant Neg - Construction Defect document preview
  • Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant Neg - Construction Defect document preview
  • Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant Neg - Construction Defect document preview
  • Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant Neg - Construction Defect document preview
  • Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant Neg - Construction Defect document preview
  • Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant Neg - Construction Defect document preview
  • Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant Neg - Construction Defect document preview
  • Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant Neg - Construction Defect document preview
						
                                

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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 -C 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 -C 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, C 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 C 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. C 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, C 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 C 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, C 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