On June 08, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
E.E. Cruz & Company, Inc.,
and
Starr Surplus Lines Insurance Company,
for Commercial - Insurance
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 10/28/2022
EXHIBIT 9
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 10/28/2022
Jimmy"
From: "Maldonado,
(DOT)"
To: "Ahmed, Mahmoud
(DOT)" Mariani"
Cc: "Zheng, Jimmy , "Jessica L.
Sarah"
, "Munier Dib , "Rotondo,
Vincent" Lorenzo"
, "De Feo, , "Green,
Rafael"
Subject: PCO #30-Bridge 719 Pier 2 Shaft 2-Differing Site Condition
Date: Thu, 31 Jan 2019 16:24:12 +0000
Importance: Normal
Attachments: Letter 29 PCO 30-Differing_Site_Condition_Bridge _719_Pier_2_Shaft_2.pdf
Mahmoud,
As discussed, see attached notice of differing site condition for 719 Pier 2 Shaft 2.
Thanks,
Jimmy Maldonado, PE
Senior Project Manager
EE Cruz & Company, Inc.
13th
32 Avenue of the Americas Floor
New York, NY 10013
Cell 908-566-2324
- FLATIRON CONFIDENTIALITY STATEMENT - The information in this email is confidential and
may be legally privileged. It isintended solely for the addressee. Access to this email by anyone else is
unauthorized. If you receive this email in error, please reply to notify me immediately. Thank you.
EECRUZ000051
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 10/28/2022
R W ä co. c
CONTRACTORS /ENGINEERS
January 31, 2019 Via email
New York State department of Transportation
Region 8 Construction Group
4 Burnett Boulevard
Poughkeepsie, New York 12603
Attention: Mr. Mahmoud Ahmed
Project Manager/Area Construction Supervisor
Reference: NYSDOT Contract D900036
Design Build 3 Bridges
Subject: Letter #29 PCO #30 Differing Site Condition Bridge 719 Pier 2 Shaft 2
Dear Mr. Ahmed:
This letter shall serve as notice that we have encountered a differing sitecondition at bridge 719 during the
installation of the caisson at pier 2 shaft 2. The CSL testing has revealed that there was an anomalous zone of
15'
approximately within the proposed socket of the shaft. Upon further investigation itappears that an
underground aquifer/stream washed the shaft socket concrete away prior to it reaching design strength. Based
on these findings itis necessary to replace this shaft with 6 additional micro piles and added concrete cap. We
will provide a cost breakdown of all the resources expended to remediate this issue as well as an impact analysis
under a separate cover. In the meantime we will continue to progress the work.
Sincerely,
Jimmy Maldonado, P.E.
Senior Project Manager
E.E. Cruz & Company, Inc.
Cell 908-566-2324
Cc: V. Rotondo, L. Defeo, J. Mariani, R. Green, file
32 Avenue of the 13* New New York 10013
Americas, Floor, York,
Tel:(212)431-3993 Fax:(212)431-3996
www.eecruz.com
Equal Opportunity Employer
EECRUZ000052
Document Filed Date
October 28, 2022
Case Filing Date
June 08, 2020
Category
Commercial - Insurance
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FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 10/28/2022 EXHIBIT 9 FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 10/28/2022 Jimmy" From: "Maldonado, (DOT)" To: "Ahmed, Mahmoud (DOT)" Mariani" Cc: "Zheng, Jimmy , "Jessica L. Sarah" , "Munier Dib , "Rotondo, Vincent" Lorenzo" , "De Feo, , "Green, Rafael" Subject: PCO #30-Bridge 719 Pier 2 Shaft 2-Differing Site Condition Date: Thu, 31 Jan 2019 16:24:12 +0000 Importance: Normal Attachments: Letter 29 PCO 30-Differing_Site_Condition_Bridge _719_Pier_2_Shaft_2.pdf Mahmoud, As discussed, see attached notice of differing site condition for 719 Pier 2 Shaft 2. Thanks, Jimmy Maldonado, PE Senior Project Manager EE Cruz & Company, Inc. 13th 32 Avenue of the Americas Floor New York, NY 10013 Cell 908-566-2324 - FLATIRON CONFIDENTIALITY STATEMENT - The information in this email is confidential and may be legally privileged. It isintended solely for the addressee. Access to this email by anyone else is unauthorized. If you receive this email in error, please reply to notify me immediately. Thank you. EECRUZ000051 FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 10/28/2022 R W ä co. c CONTRACTORS /ENGINEERS January 31, 2019 Via email New York State department of Transportation Region 8 Construction Group 4 Burnett Boulevard Poughkeepsie, New York 12603 Attention: Mr. Mahmoud Ahmed Project Manager/Area Construction Supervisor Reference: NYSDOT Contract D900036 Design Build 3 Bridges Subject: Letter #29 PCO #30 Differing Site Condition Bridge 719 Pier 2 Shaft 2 Dear Mr. Ahmed: This letter shall serve as notice that we have encountered a differing sitecondition at bridge 719 during the installation of the caisson at pier 2 shaft 2. The CSL testing has revealed that there was an anomalous zone of 15' approximately within the proposed socket of the shaft. Upon further investigation itappears that an underground aquifer/stream washed the shaft socket concrete away prior to it reaching design strength. Based on these findings itis necessary to replace this shaft with 6 additional micro piles and added concrete cap. We will provide a cost breakdown of all the resources expended to remediate this issue as well as an impact analysis under a separate cover. In the meantime we will continue to progress the work. Sincerely, Jimmy Maldonado, P.E. Senior Project Manager E.E. Cruz & Company, Inc. Cell 908-566-2324 Cc: V. Rotondo, L. Defeo, J. Mariani, R. Green, file 32 Avenue of the 13* New New York 10013 Americas, Floor, York, Tel:(212)431-3993 Fax:(212)431-3996 www.eecruz.com Equal Opportunity Employer EECRUZ000052