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.
Preview
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 10/28/2022
EXHIBIT 27
FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53DRAFT PM INDEX NO. 652321/2020
INSURED: EE CRUZ - 3 BRIDGES BR CLAIM
NYSCEF DATE OF LOSS:
DOC. NO.11/22/2018
92 For Discussion Purposes Only RECEIVED NYSCEF: 10/28/2022
REVISED CLAIM SUMMARY
Risk of Direct Physical Loss & Damage
Description Sch. Ref Soft Costs A&E Claim Preparation Total Comments
Repair Costs Impact Costs
Drilled Shaft Testing & Repair Costs
Sch. 1 $ 304,638.63 $ 304,638.63
Subcontractor Costs Sch. 2 67,459.99 561,217.11 628,677.10
Additional subcontractor costs
Project Management Sch. 3 157,662.45 823,425.85 981,088.30
Additional project management costs
Equipment Sch. 4 1,307,925.65 1,307,925.65
The total amount includes equipment directly used for repairs.
Union Labor Sch. 5 74,859.37 110,846.57 185,705.94
Additional union labor costs incurred
General Conditions Sch. 6 364,367.36 364,367.36
Extended general conditions
Safety Equipment / Small Tools
Sch. 7 134,300.71 134,300.71
The total amount includes equipment / tools directly used for repairs.
Premium labor costs incurred following the interruption period for the
Premium Labor Costs Sch. 8 100,626.75 100,626.75
duration of the project
Additional Labor Costs Sch. 9 305,772.80 305,772.80
Weather & Holiday Pay, Stair Towers, House Keeping, Snow Removal
Insurance Costs Sch. 10 5,905.54 5,905.54
Only first extension included in claim
Claim Preparation Fees Sch. 11 34,812.76 34,812.76
Claim Prep Costs Expected to be in the 80K-100K range
Additional A&E Costs Sch. 12 31,794.00 31,794.00
Costs for additional A&E services to address drilled shaft issues.
Total Claim $ 604,620.44
$ 3,708,482.79
$ 5,905.54$ 31,794.00
$ 34,812.76
$ 4,385,615.53
Less: Deductible (100,000.00)
Net Claim $ 4,285,615.53
DATE PRINTED: 10/28/2022 Page 1 of 1
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. 92 RECEIVED NYSCEF: 10/28/2022 EXHIBIT 27 FILED: NEW YORK COUNTY CLERK 10/28/2022 05:53DRAFT PM INDEX NO. 652321/2020 INSURED: EE CRUZ - 3 BRIDGES BR CLAIM NYSCEF DATE OF LOSS: DOC. NO.11/22/2018 92 For Discussion Purposes Only RECEIVED NYSCEF: 10/28/2022 REVISED CLAIM SUMMARY Risk of Direct Physical Loss & Damage Description Sch. Ref Soft Costs A&E Claim Preparation Total Comments Repair Costs Impact Costs Drilled Shaft Testing & Repair Costs Sch. 1 $ 304,638.63 $ 304,638.63 Subcontractor Costs Sch. 2 67,459.99 561,217.11 628,677.10 Additional subcontractor costs Project Management Sch. 3 157,662.45 823,425.85 981,088.30 Additional project management costs Equipment Sch. 4 1,307,925.65 1,307,925.65 The total amount includes equipment directly used for repairs. Union Labor Sch. 5 74,859.37 110,846.57 185,705.94 Additional union labor costs incurred General Conditions Sch. 6 364,367.36 364,367.36 Extended general conditions Safety Equipment / Small Tools Sch. 7 134,300.71 134,300.71 The total amount includes equipment / tools directly used for repairs. Premium labor costs incurred following the interruption period for the Premium Labor Costs Sch. 8 100,626.75 100,626.75 duration of the project Additional Labor Costs Sch. 9 305,772.80 305,772.80 Weather & Holiday Pay, Stair Towers, House Keeping, Snow Removal Insurance Costs Sch. 10 5,905.54 5,905.54 Only first extension included in claim Claim Preparation Fees Sch. 11 34,812.76 34,812.76 Claim Prep Costs Expected to be in the 80K-100K range Additional A&E Costs Sch. 12 31,794.00 31,794.00 Costs for additional A&E services to address drilled shaft issues. Total Claim $ 604,620.44 $ 3,708,482.79 $ 5,905.54$ 31,794.00 $ 34,812.76 $ 4,385,615.53 Less: Deductible (100,000.00) Net Claim $ 4,285,615.53 DATE PRINTED: 10/28/2022 Page 1 of 1