Preview
Date Filed 1/18/2024 4:19 PM.
‘Superior Court - Essex
Docket Number 2377CV00985,
COMMONWEALTH OF MAS: SACHPSETTS
ESSEX, SS SUPERIOR COURT
DOCKET NO.: 2377CV00985
CAMBRIDGE MUTUAL FIRE INSURANCE
COMPANY, as subrogee of Sherrif Showunmi,
Plaintiff,
Vv.
RODRIGUEZ CS, INC., doing business as
Rodriguez Construction Services,
Defendant.
APPLICATION FOR ENTRY OF DEFAULT JUDGMENT AND
ASSESSMENT OF DAMAGES PURSUANT TO MASS. R. CIV. P. 55(b)(2)
Pursuant to Mass. R. Civ. P. 55(b)(2), the Plaintiff Cambridge Mutual Fire Insurance
Company, hereby requests that this Court, after hearing, enter default judgment against the
Defendant Rodriguez CS, Inc. and that damages be assessed in the amount of $174,837.61.
The Plaintiff states the following in support of its application:
1 The Defendant, Rodriguez CS, Inc., is a domestic corporation having a registered
agent, Geysiane Rodriguez, 280 Wood Street, Hopkinton, ‘Massachusetts 01748, listed with
the Secretary of the Commonwealth of Massachusetts. (See attached Business Entity
Summary).
2. The Defendant is a corporation and not an individual and therefore no investigation
of military service is required. (See Attached Military Affidavit).
3 The Defendant’s registered agent, Geysiane Rodriguez, was served in-hand by a
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Deputy Sheriff of Middlesex County with a copy of the summons, together with a copy of the
Plaintiff's complaint in this matter on October 31, 2023. (ee attached Proof of Service).
CLM10796
Date Filed 1/18/2024 4:19 PM
‘Superior Court - Essex
Docket Number 2377CV00985
4. The Defendant failed to file an answer, ple: , or otherwise defend as to the
Plaintiff's complaint, or serve a copy of any answer or other|defense that they might have had,
upon Plaintiff or its attorney of record.
5 As a result, an Order of Default was entered in this case against the Defendant on
December 19, 2023. (See attached Order of Default).
6 The total amount due to the Plaintiff, exclusive of costs to be computed by the
Clerk, in this claim is $174,837.61. (See attached Statement of Damages and Affidavit of
Joseph DiBlasi).
WHEREFORE, the Plaintiff respectfully makes application that this Court enter judgment
by default and assess damages in the amount of $174,837.61 against the Defendant.
Plaintiff,
CAMBRIDGE MUTUAL FIRE
INSURANCE COMPANY,
By Its Attorney,
Crowley & McCarthy, P.C.
220 Broadway, Suite 405
Lynnfield, MA 01940
(781) 842-7308
sdildine@cmpclaw.com
CLM10796
Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985
Secretary of the Commonwealth of Massachusetts
William Francis Galvin
aes een
Business Entity Summary
ID Number: 001337057 Request certificate
Summary for: RODRIGUEZ CS INC
The exact name of the Domestic Profit Corporation: RODRIGUEZ CS INC
Entity type: Domestic Profit Corporation
Identification Number: 001337057
Date of Organization in Massachusetts: Date of Revival:
07-17-2018 ‘
Last date certain:
Current Fiscal Month/Day: 12/31 Previous Fiscal Month/Day: 12/31
The location of the Principal Office:
Address: 280 WOOD STREET
City or town, State, Zip code, HOPKINTON, MA 01748 USA
Country:
The name and address of the Registered Agent:
Name GEYSIANE CAMPAGNANI RODRIGUEZ
Address: 280 WOOD STREET
City or town, State, Zip code, HOPKINTON; MA 01748 USA
Country:
The Officers and Directors of the Corporation:
Title individual Name Address
PRESIDENT GEYSIANE CAMPAGNANI 280 WOOD STREET HOPKINTON, MA
RODRIGUEZ 01748 USA
TREASURER GEYSIANE CAMPAGNANI 280 WOOD STREET HOPKINTON, MA
RODRIGUEZ 01748 USA
SECRETARY KEVIN A RODRIGUEZ 280 WOOD STREET HOPKINTON, MA
01748 USA
VICE GEYSIANE CAMPAGNANI 280 WOOD STREET HOPKINTON, MA
PRESIDENT RODRIGUEZ 01748 USA
DIRECTOR GEYSIANE CAMPAGNANI 280 WOOD STREET HOPKINTON, MA
RODRIGUEZ 01748 USA
1
Business entity stock is publicly traded: oO
11
The total number of shares and the par value, if any, of each class of stock which
this business entity is authorized to issue:
Date Filed 1/18/2024 4:19 PM
‘Superior Court- Essex
Docket Number 2377C,V00985.
Total Authorized Total issued and
outstanding
Class of Stock Par value per share
No. of shares Total par No. of shares
alue
CNP $0 1,000 $0| 1,000
( © Confidential OMerger Oo
Consent Data Allowed Manufacturing
View filings for this business entity:
ALL FILINGS
Annual Report
Application For Revival
Articles of Amendment
Articles of Charter Surrender
ings
Comments or notes associated with this business entity:
Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Doc st Number 2377CV00985 “
CIVIL DOCKET NO. Trial Court of Massachusetis i
Summons
The Superior Court
2311 CVO0985
CASE NAME,
“ow as t-brscoll, ClerK. Clerk of Courts
of Sekt Woedial Fie. Insurance Come:aN, BS SHOE Ec
Showin
Piaintit(s)
Sesser
SS Co ADDRESS:
County
@ Coward
[Rade 08,0. dole Pecr vez, Coretnsohory Mensa Pes
5b Tedera\ Greer
Sail Cerne.
Salers, MA OGIO
Defendant(s)
~~
“Rodequez CSre. a[o[=
THIS SUMMONS IS DIRECTED TO Kaaicg jucz2. fenerchon aga Detendants name)
sent os
You being sued, The:Plaintiff(s) named above has started a lawsuit against you. A copy of the Plaintiffs Complaint filed
aga yal ait ched t
—_
is Summons and the original Gomplaint has beetrfiled in the Essex, Supeaior Court.
YOU-MUST ACT PROMPTLY TO PROTECT YOUR RIGHTS.
4. You mustrespend this lawsuit in writing within 20 days.
‘hot respond, the Court may decide the tase against you and award the Plaintiff everything asked for in the Complaint.
You will also {ae the opportunity to tell your side of the story. You must respond to this lawsuit in writing even if you expect ta
resaive this matter with the Plaintiff. f you need more time to respond, you may request an extension of time in writing
from the Court.
2. Howte Respond.
To respond to this lawsuit, you must file. a written response. with the Court and mail a copy fo the. Plaintiffs attorney (or the
Plaintiff, if unrepresented). You can do this by:
a) Filing your signed original response with the Clerk's Office for Civil Business, Essex Superior Court
Bo Federal Greet —laddres )_by mail. in person. or electronically through penne
THROORIO
the web portal www.eFileMA.com if the Complaint was e-filed through that,portal; AND
a
b) Delivering or mailingeaey of
oe response to the Plaintiffs attorriey/Piaintiff at the following address:
“OH we, Zoe. Cc.
ADSAWALY Sk Uy Pe be MA O% HO
3, What to Include in Your Response.
An "Answer" is one type of response to a Complaint, Your Answer must state whether you agree or disagree with the fact(s)
alleged in each paragraph of the Complaint. Some defenses, called affirmative e defenses; must be stated-if your Answer.or
|
you may lose your right to use them in Court. If you have any-claims against the Plaintiff (referred to-as "eounterclaims’) that
are based on the same facts or transaction described in the Complaint, then you must iricludé those claims in your Answer.
Otherwise, you may lase your right to sue the Plaintiff about anything related to this lawsuit. If you want to have your case
heard by a jury, you must specifically request a jury trial in your Court rio more than 10 days after sending your Answer.
Date Filed 1/18/2024 4:19 PM
Superior Ni Court - Essex
377 vO!
nb
3. (cont.) Another way to respond to a Complaint is by filing a “Motion to Dismiss,” if you believe that the Complaint is
legally invalid or legally insufficient. A Motion to Dismiss must be based on one of the legal deficiencies} or reasons listed
under Rule 12 of the Massachusetts Rules of Civil Procedure. If you are filing a Motion to Dismiss, you must follow
the filing rules for "Civil Motions in Superior Court," available at:
Wwww.mass.gov/law-library/massachusetts-superior-court-rules
.
4. Legal Assistance.
You may wish to get legal help from a lawyer. If you cannot get legal help, some basic information for ople who represent
themselves is available at www.mass.gov/courts/selfhelp.
5. Required Information on All Filings.
4 ~~
The "Civil Docket No." appearing at the top of this notice is the case number assigned to this case a tlmust
—.
appezr.on the
¥
front of your Answer or Motion to Dismiss. You should refer to yourself as the "Defendant."
Witness Hon. Heidi E. Brieger , Chief Justice on ~~ ff (Si eal)
|—
Clerk Thomas H. Driscoll, Jr.
‘
Note: The docket number assigned to the original Complaint by the Clerk should be stated on this Summons before itis
served on the Defendant(s). !
PROOF OF SERVICE OF PROCESS
mM
Middlesex Sheriff's Office « 40 Brick Kiln Rd, Chelmsford, MA 01824 ¢ 617-547-1171
Middlesex, ss. :
November 6, 2023
' hereby certify and return that on 10/31/2023 at 3:10 PM I served a trut é and attested copy of the SUM IMONS, COMPLAINT,
CIVIL ACTION COVER SHEET, TRACKING ORDER in this action in the following manner: To wit, by delivering in hand to
GEYSIANE RODRIGUEZ, agent, person in charge at the time of se! rvice for RODRIGUEZ CS INC DBA RODRIGUEZ
CONSTRUCTION SERVICES, at 280 WOOD ST HOPKINTON, 1, MA 01748 B . Fees: : Attest ($5.00) BiE jasic Service Fee ($30.00)
Postage and Handling ($3.00) Travel ($19.52) Conveyance ($4.50) Total: $62.02
BOd Oe
Deputy Sheriff
Date:
rev. 7/2022
Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985.
DOCKET NUMBER Trial Court of Massachusetts
DEFAULT ORDER
(Mass. R. Civ. P. 55(a)) The Superior Court
2377CV00985
CASENAME Cambridge Mutual Fire Insurance Subrogee of Sherrif Showunmi Thomas H. Driscoll, Jr., Clerk of Courts
vs. Rodriguez CS, Inc. Doing Business as,Rodriguez Construction
‘Essex County
Services
TO: COURT NAME & ADDRESS:
File Copy Essex County Superior Court - Salem
J, Michael Ruane Judicial Center
56 Federal Street
Salem, MA 01970
The party(s), named below, having failed to plead or otherwise defend the case as required by the rules of
civil procedure, and plaintiff having shown that fact by affidavit or otherwise, is(are) hereby defaulted
pursuant to Mass. R. Civ. P. 55(a).
Rodriguez CS, Inc. Doing Business as Rodriguez Construction Services
The plaintiff shall file one of the following, if not already entered:
1. in accordance with Mass. R. Civ. P. 55(b)2 and subject to Mass. R. Civ. P. 54(b) and 55(b)4,
file a motion for an assessment of damages and default judgment by, 01/18/2024.
or
2. in accordance with Mass.R.Civ.P. 55(b)(1) (for a sum certain or for a sum which can by
computation be made certain) and subject to Mass.R. Civ. P. 54(b) and 55(b)4, file a request for default
judgment by, 01/18/2024.
DATE ISSUED CLERK OF COURTS ASSISTANT CLERK t SESSION PHONEW
12/19/2023 Thomas H. Driscoll, Jr., Clerk of Court (978)825-4800
x
‘Dalai Printed: 1248-2025 189808 SoveTH ONO
Date Filed 1/18/2024 4:19 PM
Superior Court- Essex
Docket Number 2377CV00985.
COMMONWEALTH OF MASSACHUSETTS
ESSEX, SS SUPERIOR COURT
DOCKET NO.: 2377CV00985
CAMBRIDGE MUTUAL FIRE
INSURANCE COMPANY, as subrogee of
Sherrif Showunmi,
Plaintiff,
Vv.
RODRIGUEZ CS, INC., doing business as
Rodriguez Construction Services,
Defendant.
AFFIDAVIT OF MR, JOSEPH DIBLASI
J, Joseph DiBlasi, am a Claims Examiner for Cambridge Mutual Fire Insurance Company
(“Cambridge Mutual”). I haveknowledge of the facts stated herein based upon my employment
as set forth above, my actions and involvement with respect to the claim, and my review of the
claim file maintained by Cambridge Mutual with respect to this matter. I hereby state and depose
the following:
1 Cambridge Mutual paid -$174,837.61 to, or on behalf of, its insured Sheriff
Showunmi, on a claim arising from water damage that occurred on July 18, 2022, to the property
located at 4 Colonial Way, Shrewsbury, Massachusetts.
2, Attached as Exhibit J are true and accurate copies of payments made in the total
amount of $172, 337.61 (exclusive of the insured’s $2,500 deductible).
3 Attached as Exhibit 2 are true and accurate copies of the following documents in
support of the claim for property damage and living expenses in the total amount of $174,83 161:
a. Dwelling Repair Estimate - $116,660.64
Date Filed 1/18/2024 4:19 PM
‘Superior Court - Essex.
Docket Number 2377CV00985
Sylvia Electrical Contracting Proposal - $3,375.00
!
c, Contents Inventory - $30,630.73
d, Hampton Hotel Statement - $7,332.80
€. Apartment Lease - $14,572.66
f. Food Receipt Worksheet - $2,265.98
8 Damage photographs
Signed under the penalties of perjury this 17" day of January 2024.
LE
Jeséph DiB laims Examiner
me futual Fire Insurance Company
STATE OF MASSACHUSETTS
COUNTY OF ESSEX
Gdisk (naltren _
EDITH R CRABTREE
Edith R Crabtree
S
vw
NOTARY PUBLIC
Commonwealth of
Massachusetts
My Commission Expires
9/30/2027
Date Filed 1/18/2024 4:19 PM
‘Superior Court - Essex.
Docket Number 2377CV00985
EXHIBIT 1
Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985
MAIL TO:
SHERIFF SHOWUNMI
4 COLONIAL WAY
SHREWSBURY MA 01545-1523
CHECK DATE: 09/13/2022
CHECK #: 8014677
CHECK AMOUNT: $50,000.00
CLAIMANT: SHERIFF SHOWUNMI AND NAVY FEDERAL CREDIT UNION
DATE OF LOSS: 07/25/2022
FOR: BUILDING ADVANCE
POLICY #: HP14031224
CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY
AGENT #: 5276
AGENT NAME: SALEM FIVE INSURANCE SERVICES LL
AGENT ADDRESS 445 MAIN STREET SUITE 1
WOBURN MA 01801-4297
PHONE: 781 933-3100
DETACH HERE
112 09/13/2022 8014677
AMOUNT
PAY FIFTY THOUSAND AND 00/100 DOLLARS $50,000.00
PAY TO SHERIFF SHOWUNMI AND NAVY
THE FEDERAL CREDIT UNION CLM-00010796
BGA
ORDER
OF
BANK OF AMERICA AUTHORIZED SIGNATURE
80 LE 77
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Date Filed 1/18/2024 4:19 PM
‘Superior Court - Essex
Docket Number 2377CV00985
MAIL TO:
ANDERSON ADJUSTING LLC
PO BOX 718 ©
OLD LYME CT 06371-0718
CHECK DATE: 09/27/2022
CHECK #: 8015205
CHECK AMOUNT: $64,160.44
CLAIMANT: SHERIFF SHOWUNMI AND NAVY FEDERAL CREDIT UNION AND/OR THE SECRETARY OF
DATE OF LOSS: 07/25/2022
FOR: BUILDING
POLICY #: HP14031224
CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY
AGENT #: 5276
AGENT NAME: SALEM FIVE INSURANCE SERVICES LL
AGENT ADDRESS 445 MAIN STREET SUITE 1
WOBURN MA 01801-4297
PHONE: 781 933-3100
DETACH HERE
!
112 09/27/2022 8015205
AMOUNT
PAY SIXTY FOUR THOUSAND ONE HUNDRED SIXTY AND 44/100 DOLLARS _ $64,160.44
PAY TO SHERIFF SHOWUNMI AND NAVY
THE FEDERAL CREDIT UNION AND/OR ‘CLM-00010796
ORDER
OF THE SECRETARY OF
BANK OF AMERICA AUTHORIZED SIGNATURE
80 2S 20 St
j
Date Filed 1/18/2024 4:19 PM
Superior Court- Essex
Docket Number 2377CV00985
MAIL TO:
SHERIFF SHOWUNMI
4 COLONIAL WAY
SHREWSBURY MA 01545-1523
CHECK DATE: 09/13/2022
CHECK #: 8014649
CHECK AMOUNT: $3,375.00 .
CLAIMANT: SHERIFF SHOWUNMI & SYLVIA ELECTRICAL CONTRACTING
DATE OF LOSS: 07/25/2022
FOR: BLDG
POLICY #: HP14031224
CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY
AGENT #: 5276
AGENT NAME: SALEM FIVE INSURANCE SERVICES LL
AGENT ADDRESS: 445 MAIN STREET SUITE 1
WOBURN MA 01801-4297
PHONE: 781 933-3100
DETACH HERE
82-153. 09/13/2022 8014649
112
AMOUNT
PAY THREE THOUSAND THREE HUNDRED SEVENTY FIVE AND 00/100DOLLARS $3,375.00
{
PAY TO SHERIFF SHOWUNMI & SYLVIA EMERGENCY ELECTRICAL REPAIR
THE ELECTRICAL CONTRACTING ‘CLM-00010796
ORDER {
OF
|
|
ee
BANK OF AMERICA L AUTHORIZED SIGNATURE
O80 RLS TS
|
Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985
MAIL TO:
ANDERSON ADJUSTING LLC
PO BOX 718
OLD LYME CT 06371-0718
CHECK DATE: 09/27/2022
CHECK #: 8015199
CHECK AMOUNT: $37,963.53
CLAIMANT: SHERIFF SHOWUNMI
DATE OF LOSS 07/25/2022
FOR: CONTENTS & ALE i
POLICY #: HP14031224
CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY
AGENT #: 5276
AGENT NAME. SALEM FIVE INSURANCE SERVICES LL
AGENT ADDRESS 445 MAIN STREET SUITE 1
WOBURN MA 01801-4297
PHONE: 781 933-3100
DETACH HERE
112 09/27/2022 8015199
AMOUNT
PAY THIRTY SEVEN THOUSAND NINE HUNDRED SIXTY THREE AND 53/100'DOLLARS $37,963.53
PAY TO SHERIFF SHOWUNMI
THE CLM-00010796
ORDER
OF
BANK OF AMERICA AUTHORIZED SIGNATURE
804s 95:
|
Date Filed 1/18/2024 4:19 PM
‘Superior Court - Essex
Docket Number 2377CV00985
MAIL TO:
SHERIFF SHOWUNMI
4 COLONIAL WAY
SHREWSBURY MA 01545-1523
CHECK DATE: 10/25/2022
CHECK #: 8016309
CHECK AMOUNT: $8,462.62
CLAIMANT: SHERIFF SHOWUNMI
DATE OF LOSS: 07/25/2022
FOR: ALE
POLICY #: HP14031224
CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY
AGENT #: 5276
AGENT NAME: SALEM FIVE INSURANCE SERVICES LL
AGENT ADDRESS: 445 MAIN STREET SUITE 1
WOBURN MA 01801-4297
PHONE: 781 933-3100
DETACH HERE
112 10/25/2022 8016309
AMOUNT
PAY EIGHT THOUSAND FOUR HUNDRED SIXTY TWO AND 62/100 DOLLARS _ $8,462.62
PAY TO SHERIFF SHOWUNMI ALE 9/5/22— 11/30/22
|
|
THE
‘CLM-00010796
ORDER
OF 1
BANK OF AMERICA
|| AUTHORIZED SIGNATURE
1
i
:
80 253090 '' =
i
|
Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985.
MAIL TO:
SHERIFF SHOWUNMI
4 COLONIAL WAY
SHREWSBURY MA 01545-1523
CHECK DATE. 12/15/2022
CHECK #: 8018370
CHECK AMOUNT: $2,265.98
CLAIMANT: SHERIFF SHOWUNMI
DATE OF LOSS 07/25/2022
FOR: ALE ‘
POLICY #: HP14031224
CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY
AGENT #: 5276
AGENT NAME: SALEM FIVE INSURANCE SERVICES LL
AGENT ADDRESS: 445 MAIN STREET SUITE 1
y WOBURN MA 01801-4297
PHONE: 781 933-3100
DETACH HERE
112 12/15/2022 8018370
. AMOUNT
PAY TWO THOUSAND TWO HUNDRED SIXTY FIVE AND 98/100 DOLLARS ° $2,265.98
(Bn
|
PAY TO SHERIFF SHOWUNMI
THE CLM-00010796
ORDER
OF
BANK OF AMERICA AUTHORIZEDSIGNATURE
1
080 263700 a
|
Date Filed 1/18/2024 4:19 PM
‘Superior Court - Essex
Docket Number 2377CV00985:
MAIL TO:
SHERIFF SHOWUNMI
4 COLONIAL WAY
SHREWSBURY MA 01545-1523
CHECK DATE: 01/30/2023
CHECK #: 8020481
CHECK AMOUNT: $6,110.04
CLAIMANT: SHERIFF SHOWUNMI
DATE OF LOSS: 07/25/2022
FOR: ALE
POLICY #: HP14031224
CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY
AGENT #: 5276
AGENT NAME: SALEM FIVE INSURANCE SERVICES LL
AGENT ADDRESS: 445 MAIN STREET SUITE 1
WOBURN MA 01801-4297
PHONE: 781 933-3100
DETACH HERE
52153. 01/30/2023 8020481
112
AMOUNT
PAY SIX THOUSAND ONE HUNDRED TEN AND 04/100 DOLLARS $6,110.04
PAY TO SHERIFF SHOWUNMI
THE
CLM-00010796
ORDER
OF
BANK OF AMERICA AUTHORIZED SIGNATURE
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|
"80 2046 bi
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Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985
EXHIBIT 2
Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985
Anderson Adjusting LLC
P.O. Box 718
Old Lyme, CT 06371
Telephone: 860-853-8422
Fax: 860-371-3191
Insured: Sheriff Showunmi
Property: 4 Colonial Way
Shrewsbury, MA 01545
Home: 4 Colonial Way
Shrewsbury, MA 01545
Claim Rep.: Joe DiBlasi
Estimator: Mark McManus Business: (774) 766-0241
Company: Anderson Adjusting LLC E-mail: mark@andersonadjusting.
com
Claim Number: CLM-10796 Policy Number: 14031224 Type of Loss: Water
Date Contacted: 8/2/2022 12:00 AM
Date of Loss: 7/25/2022 12:00 AM Date Received: 8/2/2022 12:00 AM
Date Inspected: 8/4/2022 12:00 AM Date Entered: 8/9/2922 11:21 AM
Price List: MABO8X_JUL22 1
Restoration/Service/Remodel 1
Estimate: SHOWUNMI
This estimate is made with no commitments to repair or guarantee payment and is expressly subject to our clients final
review and approval.
‘Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985
Anderson Adjusting LLC
P.O. Box 718
Old Lyme, CT 06371
Telephone: 860-853-8422
Fax: 860-371-3191
SHOWUNMI
Dwelling
Basement
Master Bedroom LxWxH 23' 1" x 17'3" x8"
645.33 SF Walls 398.19 SF Ceiling
Q
1043.52 SF Walls & Ceiling 398.19 SF Floor
44.24 SY Flooring 80.67 LF Floor Perimeter
184.67 SF Long Wall 138.00 SF Short Wall
80.67 LF Ceil. Perimeter
DESCRIPTION QUANTITY UNIT PRICE TAX RCV DEPREC. ACV
1, R&R Recessed light fixture 14.00 EA 163,30 31.08 2,317.28 (417.12) 1,900.16
2. R&R Thermostat - High grade 1.00 EA 159.68 5.19 164.87 (0.00) 164.87
3. R&R 5/8" drywall - hung only (no tape or finish) 1,043.52 SF 2.48 45.00 2,632.93 (397.19) 2,235.74
4, R&R 5/8" drywall - hung, taped, floated, ready for 1,043.52 SF 3.64 51.52 3,849.93, (640.59) 3,209.34
paint
5. R&R Acoustical/fire-safing insulation - 4" mineral 398.19 SF 1.81 24.39 745.12 (120.36) 624.76
wool
6. R&R Batt insulation - 4" - R13 - paper / foil faced 720.85 SF 1.63 36.04 1,211.03 (190.31) 1,020.72
7, R&R Interior door unit - High grade 3.00 EA 332.94 44.92 1,043.74 (192.03) 851.71
8. Door knob/lockset - Detach & reset 3.00EA 30.91 0.00 92.73 (0.00) 92.73
9. R&R Sheathing
- plywood - 3/8" 796.38 SF 2.91 56.24 2,373.71 (342.54) 2,031.17
Above line item considers the two layers of 3/8" sub floor sheathing in the master bedroom to make it even with the rest of the basement flooring.
10. R&R Engineered wood flooring 398.19 SF 13.71 163.01 5,622.20 (848.09) 4774.11
11. Seal/prime then paint the walls and ceiling twice (3 1,043.52 SF 1.75 24.13 1,850.29 (370.06) 1,480.23
coats)
12. Paint door slab only - 2 coats (per side) 6.00 EA 50.65 3.85 307.75 (61.55) 246.20
13. Paint door/window trim & jamb - 2 coats (per side) 6.00EA 42.39 2.27 256.61 (51.32) 205.29
Totals: Master Bedroom 487.64 22,468.19 3,631.16 18,837.03
Master Bathroom LxWxH 11'9" x6" 0" x8!
297.33 SF Walls 80.29 SF Ceiling
Q
377.63 SF Walls & Ceiling 80.29 SF Floor
8.92 SY Flooring 37.17 LF Floor Perimeter
94.00 SF Long Wall 54.67 SF Short Wall
37.17 LF Ceil. Perimeter
DESCRIPTION QUANTITY UNIT PRICE TAX RCV DEPREC. ACV
14, R&R 5/8" drywall - hung only (no tape or finish) 377.63 SF 2.48 16.29 952.81 (143.74) 809.07
SHOWUNMI 9/13/2022 Page: 2
i
Date Filed 1/18/2024 4:19 PM
Superior Court - Essex
Docket Number 2377CV00985
Anderson Adjusting LLC
P.O. Box 718
Old Lyme, CT 06371
Telephone: 860-853-8422
Fax: 860-371-3191
CONTINUED - Master Bathroom
DESCRIPTION QUANTITY UNIT PRICE TAX RCV DEPREC. ACV
15, R&R 5/8" drywall - hung, taped, floated, ready for 377.63 SF 3.64 18.65 1,393.22 (231.82) 1,161.40
paint
16. R&R Acoustical/fire-safing insulation - 4" mineral 80.29 SF 1.81 4.92 150.24 (24.26) 125.98
wool
17. R&R Batt insulation - 4" - R13 - paper / foil faced 228.96 SF 1.63 11.45 384.66 (60.45) 324.21
18. Seal/prime then paint the walls and ceiling twice (3 377.63 SF 1.75 8.73 669.58 (133.92) 535.66
coats)
Totals: Master Bathroom 60.04 3,550.51 594,19 2,956.32
Hallway LxWxH 9' x 2! "xs"
«
190.67 SF Walls 26.25 SF Ceiling
216.92 SF Walls & Ceiling 26.25 SF Floor
2.92 SY Flooring 23.83 LF Floor Perimeter
72.00 SF Long Wall 23.33 SF Short Wall
Related Content
in Essex County
Ruling
Voges vs. Houser
Jul 18, 2024 |
22CV-0200010
VOGES VS. HOUSER
Case Number: 22CV-0200010
This matter is on calendar for review regarding status of judgment/dismissal. At the last hearing on June 10,
2024, the Court was informed that Plaintiff was waiting on the final Medi-Cal lien. No status report has been
filed. An appearance is necessary on today’s calendar.
Ruling
DANIEL LEE HOFFMAN, ET AL. VS GROUND RUNNERS EXPRESS, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY, ET AL.
Jul 16, 2024 |
22STCV09251
Case Number:
22STCV09251
Hearing Date:
July 16, 2024
Dept:
27
Hon. Lee S. Arian, Dept 27
Petition To Approve Minors Compromise
Hearing Date:
¿
7/16/24
Claimant Name: James Martinez, a minor
CASE NO./NAME: 22STCV09251
DANIEL LEE HOFFMAN, et al. vs GROUND RUNNERS EXPRESS, LLC
Ruling: Grant
TENTATIVE
The Court excuses the personal appearance of Claimant and the guardian ad litem. Counsel may appear by telephone or video conference call.
Under the proposed settlement, the gross settlement of $
5
,
0
00.00 is set to be distributed as follows: $
986.35
will be allocated for medical expenses, $
1,250.00
for attorneys' fees, and $
21.89
for costs. The net balance of $
2,741.76
will be awarded to Claimant.
The Court has reviewed the Petition and determined that all required information has been provided and all necessary attachments have been filed. The Court reviews the settlement and finds it fair and reasonable.
The Court also finds the attorney
s fees fair and reasonable. Based on the foregoing, the petition filed on 6/24/24 is GRANTED.
The Court sets an Order to Show Cause Re: Compliance of Payment on____________________ IN DEPARTMENT SS-27 AT 8:30 AM.
Moving party is ordered to give notice.
Ruling
ARACELI SANCHEZ, AN INDIVIDUAL VS ALICIA RIVERA, AN INDIVIDUAL
Jul 16, 2024 |
19STCV34893
Case Number:
19STCV34893
Hearing Date:
July 16, 2024
Dept:
B
Araceli sanchez V. alicia rivera
motion to Compel Discovery (x2)
Date of Hearing:
July 16, 2024
Trial Date:
July 23, 2023
Department:
B
Case No.:
19STCV34893
Moving Party:
Defendant Alicia Rivera
Responding Party:
None
BACKGROUND
On October 1, 2019, Plaintiff, Araceli Sanchez (Plaintiff), filed this action against Defendant, Alicia Rivera (Defendant) for damages arising from a motor vehicle accident.
Defendant now moves for the Court to compel Plaintiff to provide responses to Requests for Production of Documents (Set Five) and Special Interrogatories (Set Three). In connection with each motion, Defendant requests the Court to impose $3,288 in monetary sanction against Plaintiff and/or her counsel of record. Defendant also requests the Court to impose evidentiary and issue sanctions.
Trial is set for July 23, 2024.
[Tentative] Ruling
As a preliminary matter, the court finds that the instant motions are untimely. Pursuant to Code of Civil Procedure § 2024.020, any party shall be entitled as a matter of right to complete discovery proceedings on or before the 30th day, and to have motions concerning discovery heard on or before the 15th day, before the date initially set for the trial of the action. In this instance, trial is set for July 23, 2024. Therefore, any motion concerning discovery had to have been heard on or before July 8, 2024.
Defendant could have either sought to have the instant motions advanced or permitted to be heard closer to trial pursuant to Code of Civil Procedure § 2024.050, but Defendant chose to do neither. Accordingly, because the instant motions are untimely, the motions are denied.
Moving party to give notice.
Ruling
IDALIA ESPINOZA DEL CID VS FOOD 4 LESS OF CALIFORNIA, INC., ET AL.
Jul 18, 2024 |
23NWCV02507
Case Number:
23NWCV02507
Hearing Date:
July 18, 2024
Dept:
C
DEL CID v. FOOD 4 LESS OF CALIFORNIA, INC.
CASE NO.:
23NWCV02507
HEARING:
07/18/24
ADD ON
Plaintiff IDALIA ESPINOZA DEL CIDs Motion to Set Aside Dismissal under CCP §473(b) is
DENIED without prejudice
.
Moving Party to give notice.
No Opposition filed as of July 15, 2024.
This premises liability action was filed by Plaintiff on August 7, 2023. On March 26, 2024, Plaintiffs Complaint was dismissed without prejudice due to Plaintiffs Counsels failure to appear for a Case Management Conference and OSC Re: Dismissal of the Entire Action for Plaintiffs Failure to Appear on 02/27/2024. (See 03/26/24 M.O.)
Plaintiff moves to set aside the dismissal under CCP §473(b).
On June 13, 2024, this matter was CONTINUED to July 11, 2024 due to Plaintiffs failure to attach a copy of a proposed pleading or amended complaint as required by CCP §473(b). Plaintiff was given leave to file an amended Motion.
The Amended Motion filed on June 17, 2024 still does not have attached to it a proposed pleading or a copy of Plaintiffs proposed amended complaint. The Court notes that Exhibit B to the Motion does not state that it is a Proposed First Amended Complaint. Consequently, at the hearing on July 11, 2024, the Court issued the following Order:
At the hearing, Plaintiff requested, and Defendant did not oppose, a brief continuance to lodge a First Amended Complaint.
Accordingly, Plaintiff is ORDERED to lodge a First Amended Complaint by July 15, 2024.
The hearing is CONTINUED to July 18, 2024 at 9:30 a.m. in Dept. SE-C.
If lodged by July 15, 2024, the First Amended Complaint will be deemed filed on July 18, 2024. (Order, 07/11/24)
As of July 16, 2024, no First Amended Complaint has been filed/lodged with this Court.
The court may, upon any terms as may be just, relieve a party or his or her legal representative from a judgment, dismissal, order, or other proceeding taken against him or her through his or her mistake, inadvertence, surprise, or excusable neglect. Application for this relief shall be accompanied by a copy of the answer or other pleading proposed to be filed therein,
otherwise the application shall not be granted
&. (emphasis added.) (CCP §473(b).)
The Motion is DENIED without prejudice for failure to comply with the express terms of CCP §473(b).
The Motion is DENIED without prejudice due to Plaintiffs failure to attach a copy of a pleading proposed to be filed therein as required by CCP §473(b). The terms of the code are mandatory; compliance is not optional.
Ruling
ROWS AT NORTH OF MARINA ASSOCIATION vs. TAYLOR MORRISON OF CALIFORNIA, LLC
Jul 11, 2024 |
C24-00392
C24-00392
CASE NAME: ROWS AT NORTH OF MARINA ASSOCIATION VS. TAYLOR MORRISON OF CALIFORNIA,
LLC
*MOTION/PETITION TO COMPEL ARBITRATION
FILED BY: TAYLOR MORRISON OF CALIFORNIA, LLC
*TENTATIVE RULING:*
See also Line 13.
Defendants Taylor Morrison of California, LLC and William Lyon Homes, Inc. (the builder defendants)
bring this Motin to Compel Arbitration and Motion to Stay Proceedings and seek attorneys’ fees for
time and costs to bring this Motion. The Motion is opposed by Plaintiff Rows at North of Marina
Association. Various subcontractor defendants jointly submitted a Reply in support of Defendants’
SUPERIOR COURT OF CALIFORNIA, CONTRA COSTA COUNTY
MARTINEZ, CA
DEPARTMENT 12
JUDICIAL OFFICER: CHARLES S TREAT
HEARING DATE: 07/11/2024
Motion. No brief was submitted by the architect defendant.
This motion is taken off calendar for the time being, for the reasons discussed below. In short, the
problem is that the present motion puts before the Court, for present decision, only about one-third
of the overall arbitrability battle present in the case. Not only is there no pending motion that tees up
the remaining parts of the dispute for the Court’s decision, and no comprehensive briefing on those
parts – but indeed, the outcomes of those other parts of the dispute may bear directly on what result
should be reached on the present pending motion.
To explain a little more fully: The present motion is brought only by the builder defendants, Taylor
Morrison and William Lyon; and this motion seeks only to compel arbitration of plaintiff’s claims
directly against the builder defendants. If that were all there were to the case, it might make for an
easy decision to grant the arbitration motion. But the motion can’t be easily decided in that vacuum,
without considering the remainder of the case and its relation to the arbitrability issue.
Indeed, plaintiff’s only substantial ground for opposing the present motion is precisely that plaintiff
has also sued a number of other defendants – the subcontractor, and the architect – and the Court
should not force only the plaintiff-versus-builder part of the case into arbitration while the plaintiff-
versus-subcontractors part of the case remains in litigation, with the prospect of both wasteful
duplication and inconsistent results. Plaintiff argues that its claims against the subcontractors are not
themselves arbitrable. The subcontractors and builders argue, to the contrary, that plaintiff’s claims
against the subcontractors (and, presumably, any cross-complaints yet to be brought) are equally
arbitrable and ought likewise to be sent to the same arbitration. To date, however, no one has
brought any motion seeking to enforce that result, and it is less than robustly briefed at this point.
And further complicating the picture is the presence of the architect defendant. The builders and
subcontractors appear to take the position that the architect (as a “design professional”) is likewise
subject to the parties’ arbitration agreement – though it is not clear whether that means only
plaintiff’s claims against the architect, or any cross-complaints that may be brought by or against the
architect. However, it is not yet clarified whether there is any arbitration agreement to which the
architect itself was ever a signatory or party. The architect has filed no brief on the subject, but has
told the Court at CMC that it does not think it’s subject to arbitration and it is unwilling to go to
arbitration. That issue is almost entirely unbriefed at this point. Nor does the Court have a clear idea
of whether the architect portion of the overall dispute is distinct from, or factually intermingled with,
the claims brought against (or potentially by) the builders and subcontractors.
Accordingly, the Court wants to get all of these interrelated arguments before it at one time. It directs
that the parties should meet and confer about what arbitration-related motions remain to be filed,
and set a schedule for the filing and hearing of them along with the present motion. In other words,
the Court has in mind setting a deadline by which (1) the subcontractor defendants will file a motion
to compel arbitration against plaintiff, if they intend to do so; and (2) if the builders or subcontractors
will file any motion to compel arbitration against the architect, if they intend to do so. Any such
SUPERIOR COURT OF CALIFORNIA, CONTRA COSTA COUNTY
MARTINEZ, CA
DEPARTMENT 12
JUDICIAL OFFICER: CHARLES S TREAT
HEARING DATE: 07/11/2024
motions must be filed and served by August 9. The present arbitration motion will remain pending
and need not be refiled, but the parties may wish to file superseding briefs to cover both the present
motion and whatever additional motions they intend to file.
There is also the sticky point of what happens next if the Court does grant arbitration motions relating
to some, but not all, of the overall case. At the recent CMC the Court stated its general reluctance to
allow this overall construction dispute to proceed simultaneously and in parallel in both arbitration
and in litigation, if that can be helped. But there will remain the issue of whether the arbitration(s)
should be stayed in favor of the litigation, or the litigation stayed in favor or the arbitration, or neither
of those results. In this respect the Court points out the potentially conflicting demands of the FAA
and the CAA, as discussed in (for example) Rodriguez v. American Technologies, Inc. (2006) 136
Cal.App.4th 1110, 1121-22, and Cronus Investments, Inc. v. Concierge Services (2005) 35 Cal.4th 376,
393. The parties should give this point better attention in their briefing going forward.
The parties should meet and confer concerning a briefing schedule and a unified hearing date for any
arbitration-related motions (or, if no more such motions are filed, for hearing of the present pending
motion). To ensure that the case continues to move forward, the Court sets a case management
conference for October 28, 2024 at 8:30 a.m.
Ruling
JOHNSON vs RIVERSIDE COMMUNITY HOSPITAL
Jul 16, 2024 |
CVRI2303626
Motion to Compel Plaintiff to Respond to
JOHNSON vs RIVERSIDE
CVRI2303626 Form Interrogatories, Set One by
COMMUNITY HOSPITAL
RIVERSIDE COMMUNITY HOSPITAL
Tentative Ruling: The unopposed motion to compel is granted. In light of the fact that Plaintiff is
acting on a fee waiver, the Court finds that sanctions are not appropriate. Plaintiff is to provide
verified responses within thirty days without objection.
Ruling
CHRISTINA DEVELOPMENT CORPORATION, A CALIFORNIA CORPORATION VS STEVEN RAYMOND SHORT
Jul 18, 2024 |
Echo Dawn Ryan |
22STCV28564
Case Number:
22STCV28564
Hearing Date:
July 18, 2024
Dept:
26
07/18/24
Dept. 26
Rolf Treu, Judge presiding
Christina Development Corporation v. Steven Raymond Short et al.
(
22STCV28564
)
Counsel for Plaintiff/opposing party:
Steve Short, in Pro Per
Counsel for Defendants/moving party:
Debra Ellwood Meppen and Raymond L. Gill
MOTION TO STRIKE LATE AMENDMENTS TO COMPLAINT OR ALTERNATIVELY NOTICE AND STATEMENT OF DEMURRER TO PLAINTIFF STEVE SHORTS THIRD AMENDED COMPLAINT
(
filed 02/23/24) (amended notice filed on 03/08/24)
TENTATIVE RULING
The Motion To Strike Third Amended Complaint is granted.
Demurrer is moot.
I.
BACKGROUND
On September 1, 2022, Plaintiff Christina Development Corporation filed the complaint against Defendants Steve Raymond Short and Does 1 through 10 (collectively Defendants). The complaint alleges (1) tortious interference with contractual relations; (2) defamation; (3) civil harassment; (4) conversion; and (5) breach of contract.
On January 18, 2023, Plaintiff Steve Short filed the case entitled
Steve Short v. Christina Development Corporation; Christina Properties Limited, et al.
Los Angeles Superior Court, Case No. 23VECV00203 for Labor Code violations against CDC, Christina Properties Limited, G&A Partners, LTD, David Allen Whitehead, Lawrence Norman Taylor, Adam Jacob Rosenkranz, Vincent Chan, Connor Stephen Wilks, JW Associates, LLC, Empire View Homes, LLC, and Crescent Hill Lofts, LLC.
On March 10, 2023, Christina Development Corporation filed a notice of related cases with the case entitled
Steve Short v. Christina Development Corporation; Christina Properties Limited, et al.
Los Angeles Superior Court, Case No. 23VECV00203. On March 29, 2023, the Court found the two cases related and set an Order to Show Cause as to why the cases should not be consolidated. (Minute Order 3/29/23.) On April 20, 2023, the Court consolidated the two actions for all purposes. (Minute Order 4/20/23.)
On May 16, 2023, Plaintiff Steve Short filed his First Amended Complaint.
On June 12, 2023, Plaintiff Steve Short filed his Second Amended Complaint.
On January 22, 2024, Plaintiff Steve Short filed an Amended Third Complaint.
On June 5, 2024, Defendants filed a notice of non-opposition to its Motion to Strike Late Amendments to Complaint or Alternatively Notice And Statement of Demurrer to Plaintiff Steve Shorts Third Amended Complaint.
On March 8, 2024, Defendants filed the instant Motion, arguing that:
·
Plaintiffs amendments were untimely.
·
Plaintiffs Third Amended Complaint is insufficiently pled breach of contract, harassment, retaliation, hostile work environment, not paying overtime, and loan fraud.
·
Plaintiff has had four attempts at amending the Complaint.
Plaintiff has not filed an opposition as of July 17, 2024.
Defendants filed a notice of non-opposition on July 11, 2024.
II.
ANALYSIS
A.
Legal Standard for Demurrer with Motion to Strike
Motions to strike are used to reach defects or objections to pleadings that are not challengeable by demurrer (i.e., words, phrases, prayer for damages, etc.). (
See
CCP §§ 435-437.) A party may file a motion to strike in whole or in part within the time allowed to respond to a pleading, however, if a party serves and files a motion to strike without demurring to the complaint, the time to answer is extended. (CCP §§ 435(b)(1), 435(c).)
A motion to strike lies only where the pleading has irrelevant, false, or improper matter, or has not been drawn or filed in conformity with laws. (CCP § 436.) The grounds for moving to strike must appear on the face of the pleadings or by way of judicial notice. (CCP § 437.)
Demurrer
[A] demurrer tests the legal sufficiency of the allegations in a complaint. (
Lewis v. Safeway, Inc
. (2015) 235 Cal.App.4th 385, 388.) A demurrer can be used only to challenge defects that appear on the face of the pleading under attack or from matters outside the pleading that are judicially noticeable. (See
Donabedian v. Mercury Ins. Co
. (2004) 116 Cal.App.4th 968, 994 [in ruling on a demurrer, a court may not consider declarations, matters not subject to judicial notice, or documents not accepted for the truth of their contents].) For purposes of ruling on a demurrer, all facts pleaded in a complaint are assumed to be true, but the reviewing court does not assume the truth of conclusions of law. (
Aubry v. Tri-City Hosp. Dist
. (1992) 2 Cal.4th 962, 967.)
The question of plaintiff's ability to prove these allegations is of no concern at the pleadings stage. (See
Committee on Childrens Television, Inc. v. General Foods Corp
., (1983) 35 Cal.3d 197, 213-214. [It is not the ordinary function of a demurrer to test the truth of the plaintiff's allegations or the accuracy with which he describes the defendant's conduct.])
Meet and Confer
Before filing a demurrer&the demurring party shall meet and confer in person or by telephone with the party who filed the pleading that is subject to demurrer for the purpose of determining whether an agreement can be reached that would resolve the objections to be raised in the demurrer. (CCP § 430.41(a); see also CCP § 435.5 (imposing similar requirements for a motion to strike).)
Code of Civil Procedure section 435.5, subdivision (a) requires that [b]efore filing a¿motion to strike pursuant to this chapter, the moving party shall meet and confer¿in person or by telephone¿with the party who filed the pleading that is subject to the motion to strike for the purpose of determining whether an agreement can be reached that would resolve the objections to be raised in the motion to strike. The parties are to meet and confer at least five days before the date the responsive pleading is due and if they are unable to meet the demurring party shall be granted an automatic 30-day extension.¿ (Code Civ. Proc., § 435.5(a)(2).)¿ The moving party must also file and serve a declaration detailing the meet and confer efforts.¿ (
Id
.¿at (a)(3).)¿ If an amended pleading is filed, the parties must meet and confer again before a motion to strike may be filed to the amended pleading.¿ (
Id
.¿at (a).)¿
Here, Moving Defendants sufficiently met and conferred. (Princi Decl. ¶ 8, Exh. B.)
1.
Evidence in Support of the Motion
Motion to Strike
On December 14, 2023, the Court sustained Defendants demurrer to the six causes of action which are the subject of the instant demurrer, with leave to amend (the Demurrer Order). (Gill Decl. ¶ 5, Exhibit B.) The Court ordered Plaintiff to file and serve his Third Amended Complaint (TAC) by January 15, 2024, but Plaintiff filed his TAC seven days late on January 22, 2024. (Gill Decl. ¶ 5, Exhibits C & D.) Therefore, Plaintiffs TAC is untimely and should be stricken under Rule 3.1320(i) of the California Rules of Court.
Thus, the Motion to Strike is granted.
Demurrer
The demurrer is moot since the Motion to Strike was granted.
2.
Evidence in Opposition to the Motion
None.
III.
DISPOSITION
Based on the foregoing, the Court GRANTS the Motion To Strike Third Amended Complaint. Demurrer is moot.
Ruling
Austin Baker vs Future Motion, Inc.
Jul 18, 2024 |
23CV01706
23CV01706
BAKER v. FUTURE MOTION
(UNOPPOSED) PLAINTIFF BAKER’S MOTION TO APPOINT SUCCESSOR IN
INTEREST
The unopposed motion is granted. Brittany Baker, plaintiff’s surviving spouse, is
appointed plaintiff’s successor in interest in this action.
Notice to prevailing parties: Local Rule 2.10.01 requires you to submit a proposed formal order
incorporating, verbatim, the language of any tentative ruling – or attaching and incorporating the
tentative by reference - or an order consistent with the announced ruling of the Court, in
accordance with California Rule of Court 3.1312. Such proposed order is required even if the
prevailing party submitted a proposed order prior to the hearing (unless the tentative is
simply to “grant”). Failure to comply with Local Rule 2.10.01 may result in the imposition of
sanctions following an order to show cause hearing, if a proposed order is not timely filed.
Preview
Date Filed 1/18/2024 4:19 PM. ‘Superior Court - Essex Docket Number 2377CV00985, COMMONWEALTH OF MAS: SACHPSETTS ESSEX, SS SUPERIOR COURT DOCKET NO.: 2377CV00985 CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY, as subrogee of Sherrif Showunmi, Plaintiff, Vv. RODRIGUEZ CS, INC., doing business as Rodriguez Construction Services, Defendant. APPLICATION FOR ENTRY OF DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES PURSUANT TO MASS. R. CIV. P. 55(b)(2) Pursuant to Mass. R. Civ. P. 55(b)(2), the Plaintiff Cambridge Mutual Fire Insurance Company, hereby requests that this Court, after hearing, enter default judgment against the Defendant Rodriguez CS, Inc. and that damages be assessed in the amount of $174,837.61. The Plaintiff states the following in support of its application: 1 The Defendant, Rodriguez CS, Inc., is a domestic corporation having a registered agent, Geysiane Rodriguez, 280 Wood Street, Hopkinton, ‘Massachusetts 01748, listed with the Secretary of the Commonwealth of Massachusetts. (See attached Business Entity Summary). 2. The Defendant is a corporation and not an individual and therefore no investigation of military service is required. (See Attached Military Affidavit). 3 The Defendant’s registered agent, Geysiane Rodriguez, was served in-hand by a | Deputy Sheriff of Middlesex County with a copy of the summons, together with a copy of the Plaintiff's complaint in this matter on October 31, 2023. (ee attached Proof of Service). CLM10796 Date Filed 1/18/2024 4:19 PM ‘Superior Court - Essex Docket Number 2377CV00985 4. The Defendant failed to file an answer, ple: , or otherwise defend as to the Plaintiff's complaint, or serve a copy of any answer or other|defense that they might have had, upon Plaintiff or its attorney of record. 5 As a result, an Order of Default was entered in this case against the Defendant on December 19, 2023. (See attached Order of Default). 6 The total amount due to the Plaintiff, exclusive of costs to be computed by the Clerk, in this claim is $174,837.61. (See attached Statement of Damages and Affidavit of Joseph DiBlasi). WHEREFORE, the Plaintiff respectfully makes application that this Court enter judgment by default and assess damages in the amount of $174,837.61 against the Defendant. Plaintiff, CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY, By Its Attorney, Crowley & McCarthy, P.C. 220 Broadway, Suite 405 Lynnfield, MA 01940 (781) 842-7308 sdildine@cmpclaw.com CLM10796 Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985 Secretary of the Commonwealth of Massachusetts William Francis Galvin aes een Business Entity Summary ID Number: 001337057 Request certificate Summary for: RODRIGUEZ CS INC The exact name of the Domestic Profit Corporation: RODRIGUEZ CS INC Entity type: Domestic Profit Corporation Identification Number: 001337057 Date of Organization in Massachusetts: Date of Revival: 07-17-2018 ‘ Last date certain: Current Fiscal Month/Day: 12/31 Previous Fiscal Month/Day: 12/31 The location of the Principal Office: Address: 280 WOOD STREET City or town, State, Zip code, HOPKINTON, MA 01748 USA Country: The name and address of the Registered Agent: Name GEYSIANE CAMPAGNANI RODRIGUEZ Address: 280 WOOD STREET City or town, State, Zip code, HOPKINTON; MA 01748 USA Country: The Officers and Directors of the Corporation: Title individual Name Address PRESIDENT GEYSIANE CAMPAGNANI 280 WOOD STREET HOPKINTON, MA RODRIGUEZ 01748 USA TREASURER GEYSIANE CAMPAGNANI 280 WOOD STREET HOPKINTON, MA RODRIGUEZ 01748 USA SECRETARY KEVIN A RODRIGUEZ 280 WOOD STREET HOPKINTON, MA 01748 USA VICE GEYSIANE CAMPAGNANI 280 WOOD STREET HOPKINTON, MA PRESIDENT RODRIGUEZ 01748 USA DIRECTOR GEYSIANE CAMPAGNANI 280 WOOD STREET HOPKINTON, MA RODRIGUEZ 01748 USA 1 Business entity stock is publicly traded: oO 11 The total number of shares and the par value, if any, of each class of stock which this business entity is authorized to issue: Date Filed 1/18/2024 4:19 PM ‘Superior Court- Essex Docket Number 2377C,V00985. Total Authorized Total issued and outstanding Class of Stock Par value per share No. of shares Total par No. of shares alue CNP $0 1,000 $0| 1,000 ( © Confidential OMerger Oo Consent Data Allowed Manufacturing View filings for this business entity: ALL FILINGS Annual Report Application For Revival Articles of Amendment Articles of Charter Surrender ings Comments or notes associated with this business entity: Date Filed 1/18/2024 4:19 PM Superior Court - Essex Doc st Number 2377CV00985 “ CIVIL DOCKET NO. Trial Court of Massachusetis i Summons The Superior Court 2311 CVO0985 CASE NAME, “ow as t-brscoll, ClerK. Clerk of Courts of Sekt Woedial Fie. Insurance Come:aN, BS SHOE Ec Showin Piaintit(s) Sesser SS Co ADDRESS: County @ Coward [Rade 08,0. dole Pecr vez, Coretnsohory Mensa Pes 5b Tedera\ Greer Sail Cerne. Salers, MA OGIO Defendant(s) ~~ “Rodequez CSre. a[o[= THIS SUMMONS IS DIRECTED TO Kaaicg jucz2. fenerchon aga Detendants name) sent os You being sued, The:Plaintiff(s) named above has started a lawsuit against you. A copy of the Plaintiffs Complaint filed aga yal ait ched t —_ is Summons and the original Gomplaint has beetrfiled in the Essex, Supeaior Court. YOU-MUST ACT PROMPTLY TO PROTECT YOUR RIGHTS. 4. You mustrespend this lawsuit in writing within 20 days. ‘hot respond, the Court may decide the tase against you and award the Plaintiff everything asked for in the Complaint. You will also {ae the opportunity to tell your side of the story. You must respond to this lawsuit in writing even if you expect ta resaive this matter with the Plaintiff. f you need more time to respond, you may request an extension of time in writing from the Court. 2. Howte Respond. To respond to this lawsuit, you must file. a written response. with the Court and mail a copy fo the. Plaintiffs attorney (or the Plaintiff, if unrepresented). You can do this by: a) Filing your signed original response with the Clerk's Office for Civil Business, Essex Superior Court Bo Federal Greet —laddres )_by mail. in person. or electronically through penne THROORIO the web portal www.eFileMA.com if the Complaint was e-filed through that,portal; AND a b) Delivering or mailingeaey of oe response to the Plaintiffs attorriey/Piaintiff at the following address: “OH we, Zoe. Cc. ADSAWALY Sk Uy Pe be MA O% HO 3, What to Include in Your Response. An "Answer" is one type of response to a Complaint, Your Answer must state whether you agree or disagree with the fact(s) alleged in each paragraph of the Complaint. Some defenses, called affirmative e defenses; must be stated-if your Answer.or | you may lose your right to use them in Court. If you have any-claims against the Plaintiff (referred to-as "eounterclaims’) that are based on the same facts or transaction described in the Complaint, then you must iricludé those claims in your Answer. Otherwise, you may lase your right to sue the Plaintiff about anything related to this lawsuit. If you want to have your case heard by a jury, you must specifically request a jury trial in your Court rio more than 10 days after sending your Answer. Date Filed 1/18/2024 4:19 PM Superior Ni Court - Essex 377 vO! nb 3. (cont.) Another way to respond to a Complaint is by filing a “Motion to Dismiss,” if you believe that the Complaint is legally invalid or legally insufficient. A Motion to Dismiss must be based on one of the legal deficiencies} or reasons listed under Rule 12 of the Massachusetts Rules of Civil Procedure. If you are filing a Motion to Dismiss, you must follow the filing rules for "Civil Motions in Superior Court," available at: Wwww.mass.gov/law-library/massachusetts-superior-court-rules . 4. Legal Assistance. You may wish to get legal help from a lawyer. If you cannot get legal help, some basic information for ople who represent themselves is available at www.mass.gov/courts/selfhelp. 5. Required Information on All Filings. 4 ~~ The "Civil Docket No." appearing at the top of this notice is the case number assigned to this case a tlmust —. appezr.on the ¥ front of your Answer or Motion to Dismiss. You should refer to yourself as the "Defendant." Witness Hon. Heidi E. Brieger , Chief Justice on ~~ ff (Si eal) |— Clerk Thomas H. Driscoll, Jr. ‘ Note: The docket number assigned to the original Complaint by the Clerk should be stated on this Summons before itis served on the Defendant(s). ! PROOF OF SERVICE OF PROCESS mM Middlesex Sheriff's Office « 40 Brick Kiln Rd, Chelmsford, MA 01824 ¢ 617-547-1171 Middlesex, ss. : November 6, 2023 ' hereby certify and return that on 10/31/2023 at 3:10 PM I served a trut é and attested copy of the SUM IMONS, COMPLAINT, CIVIL ACTION COVER SHEET, TRACKING ORDER in this action in the following manner: To wit, by delivering in hand to GEYSIANE RODRIGUEZ, agent, person in charge at the time of se! rvice for RODRIGUEZ CS INC DBA RODRIGUEZ CONSTRUCTION SERVICES, at 280 WOOD ST HOPKINTON, 1, MA 01748 B . Fees: : Attest ($5.00) BiE jasic Service Fee ($30.00) Postage and Handling ($3.00) Travel ($19.52) Conveyance ($4.50) Total: $62.02 BOd Oe Deputy Sheriff Date: rev. 7/2022 Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985. DOCKET NUMBER Trial Court of Massachusetts DEFAULT ORDER (Mass. R. Civ. P. 55(a)) The Superior Court 2377CV00985 CASENAME Cambridge Mutual Fire Insurance Subrogee of Sherrif Showunmi Thomas H. Driscoll, Jr., Clerk of Courts vs. Rodriguez CS, Inc. Doing Business as,Rodriguez Construction ‘Essex County Services TO: COURT NAME & ADDRESS: File Copy Essex County Superior Court - Salem J, Michael Ruane Judicial Center 56 Federal Street Salem, MA 01970 The party(s), named below, having failed to plead or otherwise defend the case as required by the rules of civil procedure, and plaintiff having shown that fact by affidavit or otherwise, is(are) hereby defaulted pursuant to Mass. R. Civ. P. 55(a). Rodriguez CS, Inc. Doing Business as Rodriguez Construction Services The plaintiff shall file one of the following, if not already entered: 1. in accordance with Mass. R. Civ. P. 55(b)2 and subject to Mass. R. Civ. P. 54(b) and 55(b)4, file a motion for an assessment of damages and default judgment by, 01/18/2024. or 2. in accordance with Mass.R.Civ.P. 55(b)(1) (for a sum certain or for a sum which can by computation be made certain) and subject to Mass.R. Civ. P. 54(b) and 55(b)4, file a request for default judgment by, 01/18/2024. DATE ISSUED CLERK OF COURTS ASSISTANT CLERK t SESSION PHONEW 12/19/2023 Thomas H. Driscoll, Jr., Clerk of Court (978)825-4800 x ‘Dalai Printed: 1248-2025 189808 SoveTH ONO Date Filed 1/18/2024 4:19 PM Superior Court- Essex Docket Number 2377CV00985. COMMONWEALTH OF MASSACHUSETTS ESSEX, SS SUPERIOR COURT DOCKET NO.: 2377CV00985 CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY, as subrogee of Sherrif Showunmi, Plaintiff, Vv. RODRIGUEZ CS, INC., doing business as Rodriguez Construction Services, Defendant. AFFIDAVIT OF MR, JOSEPH DIBLASI J, Joseph DiBlasi, am a Claims Examiner for Cambridge Mutual Fire Insurance Company (“Cambridge Mutual”). I haveknowledge of the facts stated herein based upon my employment as set forth above, my actions and involvement with respect to the claim, and my review of the claim file maintained by Cambridge Mutual with respect to this matter. I hereby state and depose the following: 1 Cambridge Mutual paid -$174,837.61 to, or on behalf of, its insured Sheriff Showunmi, on a claim arising from water damage that occurred on July 18, 2022, to the property located at 4 Colonial Way, Shrewsbury, Massachusetts. 2, Attached as Exhibit J are true and accurate copies of payments made in the total amount of $172, 337.61 (exclusive of the insured’s $2,500 deductible). 3 Attached as Exhibit 2 are true and accurate copies of the following documents in support of the claim for property damage and living expenses in the total amount of $174,83 161: a. Dwelling Repair Estimate - $116,660.64 Date Filed 1/18/2024 4:19 PM ‘Superior Court - Essex. Docket Number 2377CV00985 Sylvia Electrical Contracting Proposal - $3,375.00 ! c, Contents Inventory - $30,630.73 d, Hampton Hotel Statement - $7,332.80 €. Apartment Lease - $14,572.66 f. Food Receipt Worksheet - $2,265.98 8 Damage photographs Signed under the penalties of perjury this 17" day of January 2024. LE Jeséph DiB laims Examiner me futual Fire Insurance Company STATE OF MASSACHUSETTS COUNTY OF ESSEX Gdisk (naltren _ EDITH R CRABTREE Edith R Crabtree S vw NOTARY PUBLIC Commonwealth of Massachusetts My Commission Expires 9/30/2027 Date Filed 1/18/2024 4:19 PM ‘Superior Court - Essex. Docket Number 2377CV00985 EXHIBIT 1 Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985 MAIL TO: SHERIFF SHOWUNMI 4 COLONIAL WAY SHREWSBURY MA 01545-1523 CHECK DATE: 09/13/2022 CHECK #: 8014677 CHECK AMOUNT: $50,000.00 CLAIMANT: SHERIFF SHOWUNMI AND NAVY FEDERAL CREDIT UNION DATE OF LOSS: 07/25/2022 FOR: BUILDING ADVANCE POLICY #: HP14031224 CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY AGENT #: 5276 AGENT NAME: SALEM FIVE INSURANCE SERVICES LL AGENT ADDRESS 445 MAIN STREET SUITE 1 WOBURN MA 01801-4297 PHONE: 781 933-3100 DETACH HERE 112 09/13/2022 8014677 AMOUNT PAY FIFTY THOUSAND AND 00/100 DOLLARS $50,000.00 PAY TO SHERIFF SHOWUNMI AND NAVY THE FEDERAL CREDIT UNION CLM-00010796 BGA ORDER OF BANK OF AMERICA AUTHORIZED SIGNATURE 80 LE 77 | Date Filed 1/18/2024 4:19 PM ‘Superior Court - Essex Docket Number 2377CV00985 MAIL TO: ANDERSON ADJUSTING LLC PO BOX 718 © OLD LYME CT 06371-0718 CHECK DATE: 09/27/2022 CHECK #: 8015205 CHECK AMOUNT: $64,160.44 CLAIMANT: SHERIFF SHOWUNMI AND NAVY FEDERAL CREDIT UNION AND/OR THE SECRETARY OF DATE OF LOSS: 07/25/2022 FOR: BUILDING POLICY #: HP14031224 CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY AGENT #: 5276 AGENT NAME: SALEM FIVE INSURANCE SERVICES LL AGENT ADDRESS 445 MAIN STREET SUITE 1 WOBURN MA 01801-4297 PHONE: 781 933-3100 DETACH HERE ! 112 09/27/2022 8015205 AMOUNT PAY SIXTY FOUR THOUSAND ONE HUNDRED SIXTY AND 44/100 DOLLARS _ $64,160.44 PAY TO SHERIFF SHOWUNMI AND NAVY THE FEDERAL CREDIT UNION AND/OR ‘CLM-00010796 ORDER OF THE SECRETARY OF BANK OF AMERICA AUTHORIZED SIGNATURE 80 2S 20 St j Date Filed 1/18/2024 4:19 PM Superior Court- Essex Docket Number 2377CV00985 MAIL TO: SHERIFF SHOWUNMI 4 COLONIAL WAY SHREWSBURY MA 01545-1523 CHECK DATE: 09/13/2022 CHECK #: 8014649 CHECK AMOUNT: $3,375.00 . CLAIMANT: SHERIFF SHOWUNMI & SYLVIA ELECTRICAL CONTRACTING DATE OF LOSS: 07/25/2022 FOR: BLDG POLICY #: HP14031224 CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY AGENT #: 5276 AGENT NAME: SALEM FIVE INSURANCE SERVICES LL AGENT ADDRESS: 445 MAIN STREET SUITE 1 WOBURN MA 01801-4297 PHONE: 781 933-3100 DETACH HERE 82-153. 09/13/2022 8014649 112 AMOUNT PAY THREE THOUSAND THREE HUNDRED SEVENTY FIVE AND 00/100DOLLARS $3,375.00 { PAY TO SHERIFF SHOWUNMI & SYLVIA EMERGENCY ELECTRICAL REPAIR THE ELECTRICAL CONTRACTING ‘CLM-00010796 ORDER { OF | | ee BANK OF AMERICA L AUTHORIZED SIGNATURE O80 RLS TS | Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985 MAIL TO: ANDERSON ADJUSTING LLC PO BOX 718 OLD LYME CT 06371-0718 CHECK DATE: 09/27/2022 CHECK #: 8015199 CHECK AMOUNT: $37,963.53 CLAIMANT: SHERIFF SHOWUNMI DATE OF LOSS 07/25/2022 FOR: CONTENTS & ALE i POLICY #: HP14031224 CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY AGENT #: 5276 AGENT NAME. SALEM FIVE INSURANCE SERVICES LL AGENT ADDRESS 445 MAIN STREET SUITE 1 WOBURN MA 01801-4297 PHONE: 781 933-3100 DETACH HERE 112 09/27/2022 8015199 AMOUNT PAY THIRTY SEVEN THOUSAND NINE HUNDRED SIXTY THREE AND 53/100'DOLLARS $37,963.53 PAY TO SHERIFF SHOWUNMI THE CLM-00010796 ORDER OF BANK OF AMERICA AUTHORIZED SIGNATURE 804s 95: | Date Filed 1/18/2024 4:19 PM ‘Superior Court - Essex Docket Number 2377CV00985 MAIL TO: SHERIFF SHOWUNMI 4 COLONIAL WAY SHREWSBURY MA 01545-1523 CHECK DATE: 10/25/2022 CHECK #: 8016309 CHECK AMOUNT: $8,462.62 CLAIMANT: SHERIFF SHOWUNMI DATE OF LOSS: 07/25/2022 FOR: ALE POLICY #: HP14031224 CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY AGENT #: 5276 AGENT NAME: SALEM FIVE INSURANCE SERVICES LL AGENT ADDRESS: 445 MAIN STREET SUITE 1 WOBURN MA 01801-4297 PHONE: 781 933-3100 DETACH HERE 112 10/25/2022 8016309 AMOUNT PAY EIGHT THOUSAND FOUR HUNDRED SIXTY TWO AND 62/100 DOLLARS _ $8,462.62 PAY TO SHERIFF SHOWUNMI ALE 9/5/22— 11/30/22 | | THE ‘CLM-00010796 ORDER OF 1 BANK OF AMERICA || AUTHORIZED SIGNATURE 1 i : 80 253090 '' = i | Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985. MAIL TO: SHERIFF SHOWUNMI 4 COLONIAL WAY SHREWSBURY MA 01545-1523 CHECK DATE. 12/15/2022 CHECK #: 8018370 CHECK AMOUNT: $2,265.98 CLAIMANT: SHERIFF SHOWUNMI DATE OF LOSS 07/25/2022 FOR: ALE ‘ POLICY #: HP14031224 CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY AGENT #: 5276 AGENT NAME: SALEM FIVE INSURANCE SERVICES LL AGENT ADDRESS: 445 MAIN STREET SUITE 1 y WOBURN MA 01801-4297 PHONE: 781 933-3100 DETACH HERE 112 12/15/2022 8018370 . AMOUNT PAY TWO THOUSAND TWO HUNDRED SIXTY FIVE AND 98/100 DOLLARS ° $2,265.98 (Bn | PAY TO SHERIFF SHOWUNMI THE CLM-00010796 ORDER OF BANK OF AMERICA AUTHORIZEDSIGNATURE 1 080 263700 a | Date Filed 1/18/2024 4:19 PM ‘Superior Court - Essex Docket Number 2377CV00985: MAIL TO: SHERIFF SHOWUNMI 4 COLONIAL WAY SHREWSBURY MA 01545-1523 CHECK DATE: 01/30/2023 CHECK #: 8020481 CHECK AMOUNT: $6,110.04 CLAIMANT: SHERIFF SHOWUNMI DATE OF LOSS: 07/25/2022 FOR: ALE POLICY #: HP14031224 CARRIER: CAMBRIDGE MUTUAL FIRE INSURANCE COMPANY AGENT #: 5276 AGENT NAME: SALEM FIVE INSURANCE SERVICES LL AGENT ADDRESS: 445 MAIN STREET SUITE 1 WOBURN MA 01801-4297 PHONE: 781 933-3100 DETACH HERE 52153. 01/30/2023 8020481 112 AMOUNT PAY SIX THOUSAND ONE HUNDRED TEN AND 04/100 DOLLARS $6,110.04 PAY TO SHERIFF SHOWUNMI THE CLM-00010796 ORDER OF BANK OF AMERICA AUTHORIZED SIGNATURE | | "80 2046 bi | Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985 EXHIBIT 2 Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985 Anderson Adjusting LLC P.O. Box 718 Old Lyme, CT 06371 Telephone: 860-853-8422 Fax: 860-371-3191 Insured: Sheriff Showunmi Property: 4 Colonial Way Shrewsbury, MA 01545 Home: 4 Colonial Way Shrewsbury, MA 01545 Claim Rep.: Joe DiBlasi Estimator: Mark McManus Business: (774) 766-0241 Company: Anderson Adjusting LLC E-mail: mark@andersonadjusting. com Claim Number: CLM-10796 Policy Number: 14031224 Type of Loss: Water Date Contacted: 8/2/2022 12:00 AM Date of Loss: 7/25/2022 12:00 AM Date Received: 8/2/2022 12:00 AM Date Inspected: 8/4/2022 12:00 AM Date Entered: 8/9/2922 11:21 AM Price List: MABO8X_JUL22 1 Restoration/Service/Remodel 1 Estimate: SHOWUNMI This estimate is made with no commitments to repair or guarantee payment and is expressly subject to our clients final review and approval. ‘Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985 Anderson Adjusting LLC P.O. Box 718 Old Lyme, CT 06371 Telephone: 860-853-8422 Fax: 860-371-3191 SHOWUNMI Dwelling Basement Master Bedroom LxWxH 23' 1" x 17'3" x8" 645.33 SF Walls 398.19 SF Ceiling Q 1043.52 SF Walls & Ceiling 398.19 SF Floor 44.24 SY Flooring 80.67 LF Floor Perimeter 184.67 SF Long Wall 138.00 SF Short Wall 80.67 LF Ceil. Perimeter DESCRIPTION QUANTITY UNIT PRICE TAX RCV DEPREC. ACV 1, R&R Recessed light fixture 14.00 EA 163,30 31.08 2,317.28 (417.12) 1,900.16 2. R&R Thermostat - High grade 1.00 EA 159.68 5.19 164.87 (0.00) 164.87 3. R&R 5/8" drywall - hung only (no tape or finish) 1,043.52 SF 2.48 45.00 2,632.93 (397.19) 2,235.74 4, R&R 5/8" drywall - hung, taped, floated, ready for 1,043.52 SF 3.64 51.52 3,849.93, (640.59) 3,209.34 paint 5. R&R Acoustical/fire-safing insulation - 4" mineral 398.19 SF 1.81 24.39 745.12 (120.36) 624.76 wool 6. R&R Batt insulation - 4" - R13 - paper / foil faced 720.85 SF 1.63 36.04 1,211.03 (190.31) 1,020.72 7, R&R Interior door unit - High grade 3.00 EA 332.94 44.92 1,043.74 (192.03) 851.71 8. Door knob/lockset - Detach & reset 3.00EA 30.91 0.00 92.73 (0.00) 92.73 9. R&R Sheathing - plywood - 3/8" 796.38 SF 2.91 56.24 2,373.71 (342.54) 2,031.17 Above line item considers the two layers of 3/8" sub floor sheathing in the master bedroom to make it even with the rest of the basement flooring. 10. R&R Engineered wood flooring 398.19 SF 13.71 163.01 5,622.20 (848.09) 4774.11 11. Seal/prime then paint the walls and ceiling twice (3 1,043.52 SF 1.75 24.13 1,850.29 (370.06) 1,480.23 coats) 12. Paint door slab only - 2 coats (per side) 6.00 EA 50.65 3.85 307.75 (61.55) 246.20 13. Paint door/window trim & jamb - 2 coats (per side) 6.00EA 42.39 2.27 256.61 (51.32) 205.29 Totals: Master Bedroom 487.64 22,468.19 3,631.16 18,837.03 Master Bathroom LxWxH 11'9" x6" 0" x8! 297.33 SF Walls 80.29 SF Ceiling Q 377.63 SF Walls & Ceiling 80.29 SF Floor 8.92 SY Flooring 37.17 LF Floor Perimeter 94.00 SF Long Wall 54.67 SF Short Wall 37.17 LF Ceil. Perimeter DESCRIPTION QUANTITY UNIT PRICE TAX RCV DEPREC. ACV 14, R&R 5/8" drywall - hung only (no tape or finish) 377.63 SF 2.48 16.29 952.81 (143.74) 809.07 SHOWUNMI 9/13/2022 Page: 2 i Date Filed 1/18/2024 4:19 PM Superior Court - Essex Docket Number 2377CV00985 Anderson Adjusting LLC P.O. Box 718 Old Lyme, CT 06371 Telephone: 860-853-8422 Fax: 860-371-3191 CONTINUED - Master Bathroom DESCRIPTION QUANTITY UNIT PRICE TAX RCV DEPREC. ACV 15, R&R 5/8" drywall - hung, taped, floated, ready for 377.63 SF 3.64 18.65 1,393.22 (231.82) 1,161.40 paint 16. R&R Acoustical/fire-safing insulation - 4" mineral 80.29 SF 1.81 4.92 150.24 (24.26) 125.98 wool 17. R&R Batt insulation - 4" - R13 - paper / foil faced 228.96 SF 1.63 11.45 384.66 (60.45) 324.21 18. Seal/prime then paint the walls and ceiling twice (3 377.63 SF 1.75 8.73 669.58 (133.92) 535.66 coats) Totals: Master Bathroom 60.04 3,550.51 594,19 2,956.32 Hallway LxWxH 9' x 2! "xs" « 190.67 SF Walls 26.25 SF Ceiling 216.92 SF Walls & Ceiling 26.25 SF Floor 2.92 SY Flooring 23.83 LF Floor Perimeter 72.00 SF Long Wall 23.33 SF Short Wall