Preview
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022
EXHIBIT 20
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022
Jimmy"
From: "Maldonado,
Herald"
To:
"Rodney
Joe" Joe"
Cc: "Poliafico, , "Sheehan,
Jeannine"
, "Anerella, , "Brannon,
Matthew" Michael"
, "Bonora,
Subject: FW: Builders Risk Claim-Remediation bridge 719 Pier 2 Shaft2
Date: Thu, 7 Feb 2019 14:20:41 +0000
Importance: Normal
Attachments: Pages_from_3BridgesTimeExtension_020318.pdf
Good morning Rodney,
Joe P. suggested that I reach out to you regarding the attached cost breakdown for impacts due to Caisson
remediation efforts. We are available to speak tomorrow after 1pm please advise on availability so that I can
send out an invite.
Thanks,
Jimmy Maldonado, PE
Senior Project Manager
EE Cruz & Company, Inc.
13th
32 Avenue of the Americas Floor
New York, NY 10013
Cell 732-233-8351
From: Poliafico, Joe
Sent: Thursday, February 7, 2019 8:44 AM
To: Maldonado,
Jimmy
Cc: Anerella, Jeannine ; Sheehan, Joe ; Brannon,
Matthew
Subject: Re: Builders Risk Claim-Remediation bridge 719 Pier 2 Shaft2
Rodney Herald from McGriff our broker claims person. I suggest reviewing with him prior to the
submission and make sure that we are submitting the claim properly and that allcosts fit into the correct
coverage buckets.
EECRUZ000008
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022
Joseph J. Poliafico, CSP
Vice President of Safety and Insurance
Flatiron Construction
Sent from my iPhone
On Feb 7, 2019, at 1:39 PM, Maldonado, wrote:
Jimmy
Who is Rodney?
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
From: Poliafico, Joe
Sent: Thursday, February 7, 2019 8:33 AM
To: Maldonado,
Jimmy
Cc: Anerella, Jeannine ; Sheehan, Joe ; Brannon,
Matthew
Subject: Re: Builders Risk Claim-Remediation bridge 719 Pier 2 Shaft2
Thanks Jimmy. Are you planning on reviewing with Rodney first before submission? I would recommend
that strategy.
Joseph J. Poliafico, CSP
Vice President of Safety and Insurance
Flatiron Construction
EECRUZ000009
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022
Sent from my iPhone
On Feb 7, 2019, at 1:16 PM, Maldonado, wrote:
Jimmy
Joe,
Attached for your review and comment is breakdown of allthe cost that we anticipate sending to the
insurance carrier which includes the remediation effort and all of the subsequent cost due to the impact on
our schedule. Call me if you have any questions.
Thanks,
Jimmy Maldonado, PE
Senior Project Manager
EE Cruz & Company, Inc.
13th
32 Avenue of the Americas Floor
New York, NY 10013
Cell 732-233-8351
- 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.
EECRUZ000010
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022
17. Estimation of Impact Costs for encountering Aquafer
. Impact Costs Monthly Daily
Line Description of Costs
(65 C.D) Cost Rate
1 Project Management $ 383,397.02 $ 179,410 $ 5,898
2 Staffing Costs $ 79,635.32 $ 37,265 $ 1,225
Site Indirects (Vehicles,
3 $ 109,816.70 $ 51,389 $ 1,689
ST&S, etc...)
4 Support Equipment $ 504,162.97 $ 235,922 $ 7,756
Support Labor
5 (Teamster, Bullgang, $ 807,850.27 $ 378,032 $ 12,428
etc..)
6 Subtotal: $ 1,884,862
7 Design Cost - Micropiles 50,000
$
8 Tomgraphy Testing Costs $ 20,000
9 Coring Costs $ 30,175
10 Hydro-Demolition Costs $ 57,340
11 Subtotal: $ 157,515
Micropile Work -
$ 200 000
Remedial Work (ROM)
13 Subtotal: $ 200,000
Say ROM
14 TOTAL: $ 2,242,377
$2.5M...
EECRUZ000011
Preview
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022 EXHIBIT 20 FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022 Jimmy" From: "Maldonado, Herald" To: "Rodney Joe" Joe" Cc: "Poliafico, , "Sheehan, Jeannine" , "Anerella, , "Brannon, Matthew" Michael" , "Bonora, Subject: FW: Builders Risk Claim-Remediation bridge 719 Pier 2 Shaft2 Date: Thu, 7 Feb 2019 14:20:41 +0000 Importance: Normal Attachments: Pages_from_3BridgesTimeExtension_020318.pdf Good morning Rodney, Joe P. suggested that I reach out to you regarding the attached cost breakdown for impacts due to Caisson remediation efforts. We are available to speak tomorrow after 1pm please advise on availability so that I can send out an invite. Thanks, Jimmy Maldonado, PE Senior Project Manager EE Cruz & Company, Inc. 13th 32 Avenue of the Americas Floor New York, NY 10013 Cell 732-233-8351 From: Poliafico, Joe Sent: Thursday, February 7, 2019 8:44 AM To: Maldonado, Jimmy Cc: Anerella, Jeannine ; Sheehan, Joe ; Brannon, Matthew Subject: Re: Builders Risk Claim-Remediation bridge 719 Pier 2 Shaft2 Rodney Herald from McGriff our broker claims person. I suggest reviewing with him prior to the submission and make sure that we are submitting the claim properly and that allcosts fit into the correct coverage buckets. EECRUZ000008 FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022 Joseph J. Poliafico, CSP Vice President of Safety and Insurance Flatiron Construction Sent from my iPhone On Feb 7, 2019, at 1:39 PM, Maldonado, wrote: Jimmy Who is Rodney? 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 From: Poliafico, Joe Sent: Thursday, February 7, 2019 8:33 AM To: Maldonado, Jimmy Cc: Anerella, Jeannine ; Sheehan, Joe ; Brannon, Matthew Subject: Re: Builders Risk Claim-Remediation bridge 719 Pier 2 Shaft2 Thanks Jimmy. Are you planning on reviewing with Rodney first before submission? I would recommend that strategy. Joseph J. Poliafico, CSP Vice President of Safety and Insurance Flatiron Construction EECRUZ000009 FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022 Sent from my iPhone On Feb 7, 2019, at 1:16 PM, Maldonado, wrote: Jimmy Joe, Attached for your review and comment is breakdown of allthe cost that we anticipate sending to the insurance carrier which includes the remediation effort and all of the subsequent cost due to the impact on our schedule. Call me if you have any questions. Thanks, Jimmy Maldonado, PE Senior Project Manager EE Cruz & Company, Inc. 13th 32 Avenue of the Americas Floor New York, NY 10013 Cell 732-233-8351 - 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. EECRUZ000010 FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 10/28/2022 17. Estimation of Impact Costs for encountering Aquafer . Impact Costs Monthly Daily Line Description of Costs (65 C.D) Cost Rate 1 Project Management $ 383,397.02 $ 179,410 $ 5,898 2 Staffing Costs $ 79,635.32 $ 37,265 $ 1,225 Site Indirects (Vehicles, 3 $ 109,816.70 $ 51,389 $ 1,689 ST&S, etc...) 4 Support Equipment $ 504,162.97 $ 235,922 $ 7,756 Support Labor 5 (Teamster, Bullgang, $ 807,850.27 $ 378,032 $ 12,428 etc..) 6 Subtotal: $ 1,884,862 7 Design Cost - Micropiles 50,000 $ 8 Tomgraphy Testing Costs $ 20,000 9 Coring Costs $ 30,175 10 Hydro-Demolition Costs $ 57,340 11 Subtotal: $ 157,515 Micropile Work - $ 200 000 Remedial Work (ROM) 13 Subtotal: $ 200,000 Say ROM 14 TOTAL: $ 2,242,377 $2.5M... EECRUZ000011