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Filing # 137643399 E-Filed 11/01/2021 02:02:13 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
VILLAS AT EMERALD LAKE
HOMEOWNERS ASSOCIATION, INC., a
Florida not for profit corporation,
Plaintiff,
Vv. Case No.: 2020-CA-002942
ROYAL OAK HOMES, LLC, a Florida
limited liability company; ADVANCED
WRAPPING AND CONCRETE SOLUTIONS
OF CENTRAL FLORIDA, INC., a Florida
corporation; DON KING'S CONCRETE,
INC., a Florida corporation; HUGH
MACDONALD CONSTRUCTION, INC., a
Florida corporation; IMPERIAL BUILDING
CORPORATION, a Florida corporation;
PREMIER PLASTERING OF CENTRAL
FLORIDA, INC N/K/A TGK STUCCO, INC.,
a Florida corporation; WEATHERMASTER
BUILDING PRODUCTS, INC., a Florida
corporation; WEINTRAUB INSPECTIONS &
FORENSICS, INC. N/K/A WEINTRAUB
ENGINEERING AND INSPECTIONS, INC.,
a Florida corporation; THE DIMILLO
GROUP, LLC, a Florida limited liability
company; WOLF'S IRRIGATION &
LANDSCAPING, INC., a Florida corporation;
SUMMERPARK HOMES, INC., a Florida
corporation; BROWN+COMPANY
ARCHITECTURE, INC., a Florida
corporation;
Defendants,
ROYAL OAK HOMES, LLC, a Florida
limited Liability company,
Crossclaim Plaintiff,
ADVANCED WRAPPING AND CONCRETE
SOLUTIONS OF CENTRAL FLORIDA,
INC., a Florida corporation; DON KING'S
CONCRETE, INC., a Florida corporation;
HUGH MACDONALD CONSTRUCTION,
INC., a Florida corporation; IMPERIAL
BUILDING CORPORATION, a Florida
corporation; PREMIER PLASTERING OF
CENTRAL FLORIDA, INC N/K/A TGK
STUCCO, INC., a Florida corporation;
WEATHERMASTER BUILDING
PRODUCTS, INC., a Florida corporation;
WEINTRAUB INSPECTIONS &
FORENSICS, INC. N/K/A WEINTRAUB
ENGINEERING AND INSPECTIONS, INC.,
WOLF'S IRRIGATION & LANDSCAPING,
INC., a Florida corporation;
BROWN+COMPANY ARCHITECTURE,
INC., a Florida corporation;
Crossclaim Defendants.
WEATHERMASTER BUILDING
PRODUCTS, INC., a Florida Corporation;
Third-Party Plaintiff,
Vv.
ALL GLASS INSTALLATION CORP., a
Florida Profit Corporation, CLEAR VISTA
INSTALLATION CORP., a Florida Profit
Corporation, TM CONSTRUCTION OF
SANFORD, INC., a Florida Profit
Corporation, CASEY HAWKINS GLASS,
INC. a Florida Profit Corporation, WELL
HUNG WINDOWS & DOORS, LLC. a
Florida Limited Liability Company, FRED
BOWEN CONSTRUCTION, INC., a Florida
Profit Corporation, WINGNUT
CONSTRUCTION, INC., a Florida Profit
Corporation, SOUTHERN WINDOWS, LLC.,
a Florida Limited Liability Company.
Third-Party Defendants.
/
CASEY HAWKINS GLASS’ EXPERT WITNESS DISCLOSURE
Third-party Defendant, CASEY HAWKINS GLASS, INC., by and through its attorneys,
pursuant to Paragraph 4.1 of the Complex Case Management Order dated April 29, 2021, herein
discloses the following expert:
1 Robert M. Zaralban, P.E.
SEA, Ltd.
13930 Lynmar Boulevard
Tampa, Florida 33626
See attached Construction Defect Evaluation Preliminary Report.
See attached curriculum vitae, testimony history and rate schedule.
Mr. Zaralban is available for deposition and may be coordinated through the
undersigned’s office.
[>] Michael
D. Ruel
MICHAEL D. RUEL, FL Bar No. 52835
BRENDEN C. COLLINS, Fla. Bar No.: 1025943
Galloway, Johnson, Tompkins, Burr &
Smith, APLC
400 N. Ashley Drive, Suite 1000
Tampa, Florida 33602
(813) 977-1200 + (813) 977-1288 (facsimile)
tampaservice@gallowaylawfirm.com
mruel@gallowaylawfirm.com
beollins@gallowayvlawfirm.com
Counsel for Third-Party Defendant, Casey
Hawkins Glass, Inc.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the following parties, via electronic mail, this 1 day of November 2021:
BALL JANIK LLP CARLTON FIELDS P.A.
Phillip E. Joesph, Esq. James Michael Walls, Esq.
Evan J. Small, Esq. Lannie D. Hough Jr., Esq.
Jeffrey A. Widelitz, Esq. Robin H. Leavengood, Esq.
Allana D.E. Smith, Esq. Brian C. Porter, Esq.
201 East Pine Street, Suite 600 4221 W. Boy Scout Blvd, Suite 1000
Orlando, Florida 32801 Tampa, Florida 33607
pjoseph@balljanik.com walis@ecarltonfields.com
esmall@balljanik.com rleavengood@carltonfields.com
jwidelitz@balljanik.com lhough@earltonfields.com
smith@ballianik.com bporter@ecarltonfields.com
ypalmer@balljanik.com ejohnson@carltonfields.com
cbetancourt@balljanik.com nbonilla@carltonfields.com
bburton@balljanik.com bwoolard@carltonfields.com
dmiksell @balljanik.com Counsel for Defendant, Royal Oak Homes,
orlandodocket@balljanik.com LLC
Counsel for Plaintiffs
HILL WARD HENDERSON, P.A. MOODY & GRAF, P.A.,
Timothy C. Ford, Esq. Chesley G. Moody, Jr., Esq.
Andrew E. Holway, Esq. Mai M. Le, Esq.
Rocco Cafaro, Esq. 1101 N. Lake Destiny Road, Suite 200
101 E. Kennedy Blvd., Suite 3700 Maitland, FL 32751
Tampa, Florida 33602 moody@moodygraf.com
tim.ford@hwhlaw.com mle@moodygraf.com
andrew.holway@hwhlaw.com kpollak@moodygraf.con
‘occo.cafaro@hwhlaw.com tdixon@moodygraf.com
tracy.coale@hwhlaw.com Defendant, Premier Plastering of Central
kathy.wernsing@hwh.com Florida, Inc.
derrick.calandra@hwhlaw.com
Counsel
for Weintraub Inspections &
Forensic, Inc.
LAW OFFICE OF THAMIR A. R. BUTLER WEIHMULLER KATZ CRAIG
KADDOURI, JR., P.A. LLP
Thamir A.R. Kaddouri, Jr., Esq. Denise M. Anderson, Esq.
Penelope T. Rowlett, Esq. David A. Mercer, Esq.
Beth Ann Tobey, Esq. 400 N. Ashley Drive, Suite 2300
3220 West Cypress Street Tampa, FL 33602
Tampa, Florida 33607 danderson@pbutler.legal
4
thamir.kaddouri@tampalaw.org dmercer@butler legal
service@tampalaw.org Counsel for Defendant, Don King’s Concrete,
Counsel for Defendant, Imperial Building Ine.
Corporation
CONROY SIMBERG MILBER MAKRIS PLOUSADIS &
Jayne Ann Pittman, Esq. SEIDEN, LLP
Natalie C. Fischer, Esq. Bruce R. Calderon, Esq.
Two South Orange Avenue, Suite 300 D. Bryan Hill, Esq.
Orlando, FL 32801 Audra R. Creech, Esq.
eserviceorl@conroysimberg.com 1900 NW Corporate Blvd., East Tower, Suite
jpittman@conroysimberg.com 440 Boca Raton, Florida 33431
mumaitland@conroysimberg.com bealderon@milbermakris.com
nfischer@conroysimberg.com dhill@milbermakris.com
Counsel
for Defendant, Advanced Wrapping creech@milbermakris.com
and Concrete Solutions of Central Florida, Counsel for Defendant, Brown + Company
Inc. Architecture, Inc.
Paul Sidney Elliott, Esq. LAW OFFICE OF J. CHRISTOPHER
P.O. Box 274204 NORRIS
Tampa, FL 33688-4204 Joseph L. Zollner, Esq.
pse@psejd.com PO Box 7217
Counsel
for Hugh MacDonald Construction, London, KY 40742
Ine. FloridaCDLegalMail@LibertyMutual.com
joseph.zollner@libertymutual.com
Attorney for Third-Party Defendant, Lios
Concrete Corp
HAMILTON, PRICE & MARSHALL, WRIGHT, FULFORD, MOORHEAD &
P.A BROWN, P.A.
Andrew T. Marshall, Esq. Cole J. Copertino, Esq.
Sara W. Mapes, Esq. Richard L. Russo, Esq.
2400 Manatee Ave. W. 505 Maitland Avenue, Suite 1000
Bradenton, FL 34205 Altamonte Springs, Florida 32701
Andrew@hamiltonpricelaw.com copertino@wfmblaw.com
Sara@hamiltonpricelaw.com rrusso@wfmblaw.com
atmservice@hamiltonpricelaw.com cbraungart@wfmblaw.com
Naney@hamiltonpricelaw.com lwilliams@wfmblaw.com
Kelsey@hamiltonpricelaw.com Counsel for Third-Party Defendant, Well
Counsel T&M Construction of Sanford, Inc. Hung, Windows & Doors, LLC
MILNE LAW GROUP, P.A. GROELLE & SALMON, P.A.
Peter J. Kapsales, Esq. S. Scott Ross, Esq.
Margaret M. Efta, Esq. 1715 N. Westshore Blvd. Suite 320
301 E. Pine Street, Suite 525 Tampa, FL 33607
Orlando, FL 32801 gstcourtdocs@gspalaw.coir
pkapsales@mlinelawgroup.com ross(@¢gspalaw.com
mefta@milnelawgroup.com Counsel for Defendant, Helberg Enterprises,
eservice@milnelawgroup.com LLC
Counsel for Defendant, Weathermaster
Building Products, Inc.
FISHER BOYLES, LLP LAW OFFICE OF JENNIFER L.
Wayne M. Alder, Esq. SHIPPOLE
7668 NW 125" Way Nicole Seropian, Esq.
Pompano Beach, FL 33076 Jennifer Shippole, Esq.
wayne.alder(@fisherbroyles.com 14050 NW 14th Street, Suite 180
wmalder@bellsouth.net Sunrise, Florida 33323
Counsel for Third-Party Defendant, E.R.O. jlspleadings@fednat.cor
Construction, Inc. seropian@fednat.con
jshippole@fednat.com
Counsel for Third-Party Defendant, Atlantic
Concrete Systems, Inc.
MOODY & GRAF, P.A. LAW OFFICE OF WILLIAM WOODS
Chesley G. Moody, Jr., Esq. William M. Woods, Esq.
1101 N. Lake Destiny Road, Suite 2000 100 S. Missouri Avenue, Suite 201
Maitland, FL 32751 Clearwater, FL 33756
cmoody@moodygraf.com wwoods@willwoodslaw.com
kpollak@moodygraf.com nnelm@vwillwoodslaw.con
Counsel for Third-Party Defendant, Wolfs pleadings@wiliwoodslaw.com
Irrigation & Landscaping Counsel for Third-Party Defendant, All Glass
Installation Corp.
2 Michael Ruck
MICHAEL D. RUEL
BRENDEN C. COLLINS
TH
INVESTIGATION, RESEARCH AND TESTING
Since 1970 ANNIVERSARY
zo 1970 ~ 2020
Construction Defect Evaluation
Preliminary Report
Casey Hawkins Glass, Inc.
Location: Villas at Emerald Lake
Kissimmee, Florida
Prepared for:
Mr. Michael Ruel
Galloway Law Firm
400 North Ashley Drive, Suite 1000
Tampa, Florida 33602
Case No. 2020-CA-002942
S-E-A Matter No. 04.116952
Issue Date: November 1, 2021
poe RCRA CCC CRC re mer ky cuts Sevkpd e ta Tia uy
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Table of Contents
List of Figures.
| Executive Summary
Matter Assignment
Scope..
Methodology
Conclusions .
Signatures..
IL Procedures seeeeenee
WM Discussion seeeeaees a
Background Information ....
Review of Casey Hawkins' Scope of Work 10
Review of Alleged Defects...... 13
Review of Sampling 18
Marcon Item 2.0101 - Window Fails Dam Test a 19
Marcon Item 2.0102 - Window Fails Spray Test .... 20
Marcon Item 2.0103 - Lack of Sealant Under Window Fin 20
Marcon Item 2.0112 - Damaged Window Fin 21
Marcon Item 2.0116 - Incorrect Type of Window Installed a 21
Marcon Item 3.0120 - Inadequate Installation of Flashing Around Window Perimeter.. 22
Marcon Item 3.0202 - Improper Application of Secondary Sealant Around Window 22
Evaluation of Windows.......... 26
Evaluation of SMH Proposed Repairs. 28
Appendi: 30
List of Attachments 30
S-E-A Matter No. 04.116952
Issue Date: November 1, 2021 2 of 30
List of Figures
Figure 1: Aerial view of Villas at Emerald Lake (image obtained from OCPA). ....... 10
Figure 2: Lots 142 to 149 (image obtained from OCPA).... 12
Figure 3: Lots 182 to 189 (image obtained from OCPA). 12
Figure 4: Marcon Photograph VEmdD30138.JPG at Marcon Cut 408. 23
Figure 5: Marcon Photograph VEmdD30143.JPG at Marcon Cut 408. 24
S-E-A Matter No. 04.116952
Issue Date: November 1, 2021 3 of 30
I. Executive Summary
Matter Assignment
On September 13, 2021, SEA, Ltd. (S-E-A) was requested by Mr. Michael Ruel of Galloway Law
Firm, Tampa, Florida, to evaluate alleged construction defects at Villas at Emerald Lake, located
in Kissimmee, Florida. This evaluation was conducted by Mr. Robert M. Zaralban, P.E., Senior
Civil/Structural Engineer, as S-E-A Matter No. 04.116952.
Scope
Specifically, S-E-A was requested to evaluate the alleged deficiencies in the work product of
Casey Hawkins Glass, Inc. (Casey Hawkins), if the alleged deficiencies have resulted in damage to
the buildings, and to evaluate proposed repairs related to the alleged deficiencies.
Methodology
The methodology utilized by S-E-A during the investigation of this incident was in accordance
with The Scientific Method and applicable principles. The investigation and analysis of any
incident is a complex and scientific endeavor. The methodology of such an endeavor, therefore,
must include the comprehensive, objective, and accurate compilation and analysis of the
available data.
Conclusions
The documents reviewed indicate there is not sufficient data, testing, and/or evaluations
to substantiate the allegation that the alleged deficiencies at Villas at Emerald Lake are
related to deficiencies in the work product of Casey Hawkins Glass, Inc., or that these
alleged deficiencies have resulted in damage to the buildings.
The documents reviewed indicate there is not sufficient data, testing, and/or evaluations
to reasonably evaluate the scope of the SMH Construction Services estimated cost of
repairs for Villas at Emerald Lake, or the extent to which these costs are associated with
deficiencies in the work product of Casey Hawkins Glass, Inc.
The data, testing, and analysis provided in the Marcon Report does not justify full removal
and replacement of the windows installed by Casey Hawkins Glass, Inc.
S-E-A Matter No. 04.116952 Silas
Issue Date: November 1, 2021 4 of 30
Signatures
S-E-A and the undersigned hereby certify the opinions and conclusions expressed herein were
formed to a reasonable degree of professional certainty. They are based upon the application of
reliable principles and scientific methodologies to all of the facts known by S-E-A and the
undersigned when this report was issued, as well as knowledge, skill, experience, training and/or
education. Should additional information be discovered, S-E-A and the undersigned reserve the
right to appropriately amend or augment these findings.
Prepared By: Technically Reviewed By:
Robert M, Laralban / ju RichardWU. Meyorou
| eu
Robert M. Zaralban, P.E. Richard M. Meyerson
Senior Civil/Structural Engineer
State of Florida
License No. 54106
SEA, LTD. CO
7001 Buffalo Parkway
Columbus, Ohio 43229
COA No. 8430
S-E-A Matter No. 04.116952
Issue Date: November 1, 2021 5 of 30
Il. Procedures
1. S-E-A reviewed various documents, including the following:
. filings relating to "Villas at Emerald Lake Homeowners Association, Inc. v. Royal Oak
Homes, LLC, Weathermaster Building Products, Inc., et al. v. Casey Hawkins Glass, Inc.,
et al.", Case No. 2020-CA-002942, in the Circuit Court of the Ninth Judicial Circuit in and
for Osceola County, Florida, including:
. "Amended Complaint and Demand for Jury Trial", dated April 30, 2021 (Association's
Amended Complaint);
"Royal Oak Homes, LLC's Answer and Defenses to Plaintiff's Amended Complaint
and Amended Crossclaim Complaint", dated May 20, 2021 (ROH Amended
Crossclaim);
"Weathermaster Building Products, Inc.'s Third-Party Complaint", dated January 18,
2021 (Weathermaster Third-Party Complaint);
"Plaintiff's Expert Witness Disclosure", dated April 21, 2021 (Association's Expert
Witness Disclosure);
"Defendant/Crossclaim Plaintiff Royal Oak Homes, LLC's Designation of Experts",
dated September 10, 2021 (ROH's Expert Witness Disclosure);
"Defendant/Crossclaim Plaintiff Royal Oak Homes, LLC's Notice of Filing Expert
Report", dated September 13, 2021; and
"Defendant/Third-Party Plaintiff, Weathermaster Building Products, Inc.'s Notice of
Filing Expert Witness Disclosure", dated October 1, 2021 (Weathermaster's Expert
Witness Disclosure);
"Weathermaster Building Products, Inc. Independent Contract Agreement" between
Weathermaster Building Products, Inc. (Weathermaster) and Casey Hawkins, dated
February 23, 2015;
construction drawings for Lots 110 to 149 and 162 to 197 prepared for Royal Oak Homes
by Brown + Company Architecture (BCA) (ROH Buildings);
various Florida Product Approvals for windows manufactured by MI Windows and
Doors (MI);
S-E-A Matter No. 04.116952 Silas
Issue Date: November 1, 2021 6 of 30
. documents prepared on behalf of Villas at Emerald Lake Homeowners Association,
Inc. (Association), including:
. documents prepared by Marcon Forensics (Marcon), including:
. "Engineering Assessment Report", dated April 28, 2020;
. "Engineering Assessment Report", dated April 2, 2021 (Marcon Report);
"Villas at Emerald Lake, Non-Defect", dated June 15, 2021 (Marcon Defect
Matrix); and
. documents produced during discovery;
. documents prepared by SMH Construction Services, Inc. (SMH), including:
. "Villas at Emerald Lake, Preliminary Estimate - ROH Homes", dated April 5, 2021
(SMH ROH Estimate); and
. documents produced during discovery;
documents prepared by and on behalf of Weathermaster, including:
. Villas at Emerald Lake Payment Records;
. “Expert Report", prepared by RHBj Consulting, LLC (RHBj), dated September 29,
2021 (RHBj Report); and
. documents produced during discovery;
documents prepared on behalf of other parties, including:
. "Evaluation Report", prepared by Alta Engineering Company (Alta), dated
September 10, 2021 (Alta Report); and
. "NVS5 Preliminary Expert Report", prepared by NV5, Inc. on behalf of Weintraub
Inspections and Forensic, Inc., dated October 1, 2021;
information obtained from the Osceola County Property Appraiser's (OCPA) website;
aerial views of the community obtained from Google Maps and Bing Maps;
portions of the following:
. documents produced by American Architectural Manufacturer's Association,
including:
. AAMA 501.2-15, "Quality Assurance and Diagnostic Water Leakage Field Check
of Installed Storefronts, Curtain Walls and Glazing Systems";
AAMA 502-12, "Voluntary Specification for Field Testing of Newly Installed
Fenestration Products"; and
S-E-A Matter No. 04.116952 Silas
Issue Date: November 1, 2021 7 of 30
. AAMA 511-08, "Voluntary Guideline for Forensic Water Penetration Testing of
Fenestration Products";
. documents produced by ASTM International, including:
. ASTM E2128-17, "Standard Guide for Evaluating Water Leakage of Building
Walls"; and
various building codes, including:
. Florida Building Code - Building, 2010 Edition (2010 FBC);
. Florida Building Code - Residential, 2010 Edition (2010 FRC);
. Florida Building Code - Building, 2014 Edition (2014 FBC);
Florida Building Code - Residential, 2014 Edition (2014 FRC); and
Florida Building Code - Existing Building, 7th Edition (2020).
S-E-A Matter No. 04.116952 Silas
Issue Date: November 1, 2021 8 of 30
II. Discussion
Background Information
Villas at Emerald Lake is a residential community consisting of twelve, two-story townhome
buildings. Included as Figure 1 is an aerial view of the community from OCPA. Ten of the
buildings were constructed by Royal Oak Homes, LLC (ROH) between 2015 and 2017. The two
remaining buildings were constructed by The Damilola Group in 2008.
The first-floor exterior walls of the ROH buildings are primarily constructed of concrete masonry
unit (CMU) and finished with painted, direct-applied stucco. The second-floor exterior walls are
constructed with wood frame and OSB sheathing and finished with painted stucco-over-lath.
Based on the documents reviewed, ROH was the developer and general contractor for the ROH
buildings. The construction plans for the ROH buildings were prepared by BCA. The ROH
buildings were designed per the 2010 or 2014 Florida Building Code - Residential. ROH hired
various subcontractors to construct the buildings including Weathermaster to supply and install
windows. Weathermaster hired various subcontractors to install the windows, one of which
was Casey Hawkins. Further discussion of Casey Hawkins' scope of work is addressed in the
following section of this report.
Based on the documents produced by Marcon, the windows are single-hung and mulled, single-
hung Series GA 195, manufactured by MI Windows and Doors, LLC.
S-E-A Matter No. 04.116952 Silas
Issue Date: November 1, 2021 9 of 30
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Figure 1: Aerial view of Villas at Emerald Lake (image obtained from OCPA).
Review of Casey Hawkins' Scope of Work
Included as Attachment 1 to this report is the contract between Weathermaster and Casey
Hawkins which was included in Exhibit C of the Weathermaster Third-Party Complaint. A review
of this contract indicates there was no specific scope of work defined for Casey Hawkins.
Included as Attachment 2 to this report are Weathermaster's payment records which were
included in Exhibit D of the Weathermaster Third-Party Complaint. Based on a review of the
payment records, Casey Hawkins performed work on two, 8-unit buildings, specifically, the lots,
as identified in Table 1. Aerial views of these buildings are included as Figure 2 and Figure 3 and
identified in Figure 1. Of the sixteen units worked on by Casey Hawkins, five of those units (as
S-E-A Matter No. 04.116952 icles
Issue Date: November 1, 2021 10 of 30
identified in Table 1) had additional contractors involved in window installation. At the time of
this report, the specific scope of work for each contractor in these units remains undetermined.
Based on the payment records, the window installations performed by Casey Hawkins were
invoiced on June 5, 2015 and May 27, 2016. The payment records do not identify any specific
scope of work for Casey Hawkins.
Casey Hawkins was not involved with the construction of The Damilola Group buildings.
“Florida | Certificate Other
Lot / : Address "Residential of ‘Subcontractors,
Code Occupancy
12 2890 Tanzanite Terrace 2014 8/20/15 Well Done
143 2888 Tanzanite Terrace 2014 8/20/15 Well Done
144 2886 Tanzanite Terrace 2014 1/26/16 Well Done
145 2884 Tanzanite Terrace 2014 12/8/15 Well Done
146 2882 Tanzanite Terrace 2014 11/6/15
147 2880 Tanzanite Terrace 2014 12/9/15
148 2878 Tanzanite Terrace 2014 2/2/16
149 2876 Tanzanite Terrace 2014 8/28/15
182 2897 Sunstone Drive 2014 9/15/16
183 2899 Sunstone Drive 2014 9/19/16
184 2901 Sunstone Drive 2014 9/15/16
185 2903 Sunstone Drive 2014 9/15/16
186 2905 Sunstone Drive 2014 9/19/16
187 2907 Sunstone Drive 2014 9/21/16 Well Hung
188 2909 Sunstone Drive 2014 9/19/16
189 2911 Sunstone Drive 2014 9/19/16
Table 1: Building information for Casey Hawkins at Villas at Emerald Lake.
S-E-A Matter No. 04.116952 Silas
Issue Date: November 1, 2021 11 of 30
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4
S-E-A Matter No. 04.116952 icles
Issue Date: November 1, 2021 12 of 30
Review of
Preview
Filing # 137643399 E-Filed 11/01/2021 02:02:13 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION, INC., a Florida not for profit corporation, Plaintiff, Vv. Case No.: 2020-CA-002942 ROYAL OAK HOMES, LLC, a Florida limited liability company; ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC., a Florida corporation; DON KING'S CONCRETE, INC., a Florida corporation; HUGH MACDONALD CONSTRUCTION, INC., a Florida corporation; IMPERIAL BUILDING CORPORATION, a Florida corporation; PREMIER PLASTERING OF CENTRAL FLORIDA, INC N/K/A TGK STUCCO, INC., a Florida corporation; WEATHERMASTER BUILDING PRODUCTS, INC., a Florida corporation; WEINTRAUB INSPECTIONS & FORENSICS, INC. N/K/A WEINTRAUB ENGINEERING AND INSPECTIONS, INC., a Florida corporation; THE DIMILLO GROUP, LLC, a Florida limited liability company; WOLF'S IRRIGATION & LANDSCAPING, INC., a Florida corporation; SUMMERPARK HOMES, INC., a Florida corporation; BROWN+COMPANY ARCHITECTURE, INC., a Florida corporation; Defendants, ROYAL OAK HOMES, LLC, a Florida limited Liability company, Crossclaim Plaintiff, ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC., a Florida corporation; DON KING'S CONCRETE, INC., a Florida corporation; HUGH MACDONALD CONSTRUCTION, INC., a Florida corporation; IMPERIAL BUILDING CORPORATION, a Florida corporation; PREMIER PLASTERING OF CENTRAL FLORIDA, INC N/K/A TGK STUCCO, INC., a Florida corporation; WEATHERMASTER BUILDING PRODUCTS, INC., a Florida corporation; WEINTRAUB INSPECTIONS & FORENSICS, INC. N/K/A WEINTRAUB ENGINEERING AND INSPECTIONS, INC., WOLF'S IRRIGATION & LANDSCAPING, INC., a Florida corporation; BROWN+COMPANY ARCHITECTURE, INC., a Florida corporation; Crossclaim Defendants. WEATHERMASTER BUILDING PRODUCTS, INC., a Florida Corporation; Third-Party Plaintiff, Vv. ALL GLASS INSTALLATION CORP., a Florida Profit Corporation, CLEAR VISTA INSTALLATION CORP., a Florida Profit Corporation, TM CONSTRUCTION OF SANFORD, INC., a Florida Profit Corporation, CASEY HAWKINS GLASS, INC. a Florida Profit Corporation, WELL HUNG WINDOWS & DOORS, LLC. a Florida Limited Liability Company, FRED BOWEN CONSTRUCTION, INC., a Florida Profit Corporation, WINGNUT CONSTRUCTION, INC., a Florida Profit Corporation, SOUTHERN WINDOWS, LLC., a Florida Limited Liability Company. Third-Party Defendants. / CASEY HAWKINS GLASS’ EXPERT WITNESS DISCLOSURE Third-party Defendant, CASEY HAWKINS GLASS, INC., by and through its attorneys, pursuant to Paragraph 4.1 of the Complex Case Management Order dated April 29, 2021, herein discloses the following expert: 1 Robert M. Zaralban, P.E. SEA, Ltd. 13930 Lynmar Boulevard Tampa, Florida 33626 See attached Construction Defect Evaluation Preliminary Report. See attached curriculum vitae, testimony history and rate schedule. Mr. Zaralban is available for deposition and may be coordinated through the undersigned’s office. [>] Michael D. Ruel MICHAEL D. RUEL, FL Bar No. 52835 BRENDEN C. COLLINS, Fla. Bar No.: 1025943 Galloway, Johnson, Tompkins, Burr & Smith, APLC 400 N. Ashley Drive, Suite 1000 Tampa, Florida 33602 (813) 977-1200 + (813) 977-1288 (facsimile) tampaservice@gallowaylawfirm.com mruel@gallowaylawfirm.com beollins@gallowayvlawfirm.com Counsel for Third-Party Defendant, Casey Hawkins Glass, Inc. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the following parties, via electronic mail, this 1 day of November 2021: BALL JANIK LLP CARLTON FIELDS P.A. Phillip E. Joesph, Esq. James Michael Walls, Esq. Evan J. Small, Esq. Lannie D. Hough Jr., Esq. Jeffrey A. Widelitz, Esq. Robin H. Leavengood, Esq. Allana D.E. Smith, Esq. Brian C. Porter, Esq. 201 East Pine Street, Suite 600 4221 W. Boy Scout Blvd, Suite 1000 Orlando, Florida 32801 Tampa, Florida 33607 pjoseph@balljanik.com walis@ecarltonfields.com esmall@balljanik.com rleavengood@carltonfields.com jwidelitz@balljanik.com lhough@earltonfields.com smith@ballianik.com bporter@ecarltonfields.com ypalmer@balljanik.com ejohnson@carltonfields.com cbetancourt@balljanik.com nbonilla@carltonfields.com bburton@balljanik.com bwoolard@carltonfields.com dmiksell @balljanik.com Counsel for Defendant, Royal Oak Homes, orlandodocket@balljanik.com LLC Counsel for Plaintiffs HILL WARD HENDERSON, P.A. MOODY & GRAF, P.A., Timothy C. Ford, Esq. Chesley G. Moody, Jr., Esq. Andrew E. Holway, Esq. Mai M. Le, Esq. Rocco Cafaro, Esq. 1101 N. Lake Destiny Road, Suite 200 101 E. Kennedy Blvd., Suite 3700 Maitland, FL 32751 Tampa, Florida 33602 moody@moodygraf.com tim.ford@hwhlaw.com mle@moodygraf.com andrew.holway@hwhlaw.com kpollak@moodygraf.con ‘occo.cafaro@hwhlaw.com tdixon@moodygraf.com tracy.coale@hwhlaw.com Defendant, Premier Plastering of Central kathy.wernsing@hwh.com Florida, Inc. derrick.calandra@hwhlaw.com Counsel for Weintraub Inspections & Forensic, Inc. LAW OFFICE OF THAMIR A. R. BUTLER WEIHMULLER KATZ CRAIG KADDOURI, JR., P.A. LLP Thamir A.R. Kaddouri, Jr., Esq. Denise M. Anderson, Esq. Penelope T. Rowlett, Esq. David A. Mercer, Esq. Beth Ann Tobey, Esq. 400 N. Ashley Drive, Suite 2300 3220 West Cypress Street Tampa, FL 33602 Tampa, Florida 33607 danderson@pbutler.legal 4 thamir.kaddouri@tampalaw.org dmercer@butler legal service@tampalaw.org Counsel for Defendant, Don King’s Concrete, Counsel for Defendant, Imperial Building Ine. Corporation CONROY SIMBERG MILBER MAKRIS PLOUSADIS & Jayne Ann Pittman, Esq. SEIDEN, LLP Natalie C. Fischer, Esq. Bruce R. Calderon, Esq. Two South Orange Avenue, Suite 300 D. Bryan Hill, Esq. Orlando, FL 32801 Audra R. Creech, Esq. eserviceorl@conroysimberg.com 1900 NW Corporate Blvd., East Tower, Suite jpittman@conroysimberg.com 440 Boca Raton, Florida 33431 mumaitland@conroysimberg.com bealderon@milbermakris.com nfischer@conroysimberg.com dhill@milbermakris.com Counsel for Defendant, Advanced Wrapping creech@milbermakris.com and Concrete Solutions of Central Florida, Counsel for Defendant, Brown + Company Inc. Architecture, Inc. Paul Sidney Elliott, Esq. LAW OFFICE OF J. CHRISTOPHER P.O. Box 274204 NORRIS Tampa, FL 33688-4204 Joseph L. Zollner, Esq. pse@psejd.com PO Box 7217 Counsel for Hugh MacDonald Construction, London, KY 40742 Ine. FloridaCDLegalMail@LibertyMutual.com joseph.zollner@libertymutual.com Attorney for Third-Party Defendant, Lios Concrete Corp HAMILTON, PRICE & MARSHALL, WRIGHT, FULFORD, MOORHEAD & P.A BROWN, P.A. Andrew T. Marshall, Esq. Cole J. Copertino, Esq. Sara W. Mapes, Esq. Richard L. Russo, Esq. 2400 Manatee Ave. W. 505 Maitland Avenue, Suite 1000 Bradenton, FL 34205 Altamonte Springs, Florida 32701 Andrew@hamiltonpricelaw.com copertino@wfmblaw.com Sara@hamiltonpricelaw.com rrusso@wfmblaw.com atmservice@hamiltonpricelaw.com cbraungart@wfmblaw.com Naney@hamiltonpricelaw.com lwilliams@wfmblaw.com Kelsey@hamiltonpricelaw.com Counsel for Third-Party Defendant, Well Counsel T&M Construction of Sanford, Inc. Hung, Windows & Doors, LLC MILNE LAW GROUP, P.A. GROELLE & SALMON, P.A. Peter J. Kapsales, Esq. S. Scott Ross, Esq. Margaret M. Efta, Esq. 1715 N. Westshore Blvd. Suite 320 301 E. Pine Street, Suite 525 Tampa, FL 33607 Orlando, FL 32801 gstcourtdocs@gspalaw.coir pkapsales@mlinelawgroup.com ross(@¢gspalaw.com mefta@milnelawgroup.com Counsel for Defendant, Helberg Enterprises, eservice@milnelawgroup.com LLC Counsel for Defendant, Weathermaster Building Products, Inc. FISHER BOYLES, LLP LAW OFFICE OF JENNIFER L. Wayne M. Alder, Esq. SHIPPOLE 7668 NW 125" Way Nicole Seropian, Esq. Pompano Beach, FL 33076 Jennifer Shippole, Esq. wayne.alder(@fisherbroyles.com 14050 NW 14th Street, Suite 180 wmalder@bellsouth.net Sunrise, Florida 33323 Counsel for Third-Party Defendant, E.R.O. jlspleadings@fednat.cor Construction, Inc. seropian@fednat.con jshippole@fednat.com Counsel for Third-Party Defendant, Atlantic Concrete Systems, Inc. MOODY & GRAF, P.A. LAW OFFICE OF WILLIAM WOODS Chesley G. Moody, Jr., Esq. William M. Woods, Esq. 1101 N. Lake Destiny Road, Suite 2000 100 S. Missouri Avenue, Suite 201 Maitland, FL 32751 Clearwater, FL 33756 cmoody@moodygraf.com wwoods@willwoodslaw.com kpollak@moodygraf.com nnelm@vwillwoodslaw.con Counsel for Third-Party Defendant, Wolfs pleadings@wiliwoodslaw.com Irrigation & Landscaping Counsel for Third-Party Defendant, All Glass Installation Corp. 2 Michael Ruck MICHAEL D. RUEL BRENDEN C. COLLINS TH INVESTIGATION, RESEARCH AND TESTING Since 1970 ANNIVERSARY zo 1970 ~ 2020 Construction Defect Evaluation Preliminary Report Casey Hawkins Glass, Inc. Location: Villas at Emerald Lake Kissimmee, Florida Prepared for: Mr. Michael Ruel Galloway Law Firm 400 North Ashley Drive, Suite 1000 Tampa, Florida 33602 Case No. 2020-CA-002942 S-E-A Matter No. 04.116952 Issue Date: November 1, 2021 poe RCRA CCC CRC re mer ky cuts Sevkpd e ta Tia uy ys a orere see tia eis \cio) rc Va Mites ee Gps Due) oe erie ars Table of Contents List of Figures. | Executive Summary Matter Assignment Scope.. Methodology Conclusions . Signatures.. IL Procedures seeeeenee WM Discussion seeeeaees a Background Information .... Review of Casey Hawkins' Scope of Work 10 Review of Alleged Defects...... 13 Review of Sampling 18 Marcon Item 2.0101 - Window Fails Dam Test a 19 Marcon Item 2.0102 - Window Fails Spray Test .... 20 Marcon Item 2.0103 - Lack of Sealant Under Window Fin 20 Marcon Item 2.0112 - Damaged Window Fin 21 Marcon Item 2.0116 - Incorrect Type of Window Installed a 21 Marcon Item 3.0120 - Inadequate Installation of Flashing Around Window Perimeter.. 22 Marcon Item 3.0202 - Improper Application of Secondary Sealant Around Window 22 Evaluation of Windows.......... 26 Evaluation of SMH Proposed Repairs. 28 Appendi: 30 List of Attachments 30 S-E-A Matter No. 04.116952 Issue Date: November 1, 2021 2 of 30 List of Figures Figure 1: Aerial view of Villas at Emerald Lake (image obtained from OCPA). ....... 10 Figure 2: Lots 142 to 149 (image obtained from OCPA).... 12 Figure 3: Lots 182 to 189 (image obtained from OCPA). 12 Figure 4: Marcon Photograph VEmdD30138.JPG at Marcon Cut 408. 23 Figure 5: Marcon Photograph VEmdD30143.JPG at Marcon Cut 408. 24 S-E-A Matter No. 04.116952 Issue Date: November 1, 2021 3 of 30 I. Executive Summary Matter Assignment On September 13, 2021, SEA, Ltd. (S-E-A) was requested by Mr. Michael Ruel of Galloway Law Firm, Tampa, Florida, to evaluate alleged construction defects at Villas at Emerald Lake, located in Kissimmee, Florida. This evaluation was conducted by Mr. Robert M. Zaralban, P.E., Senior Civil/Structural Engineer, as S-E-A Matter No. 04.116952. Scope Specifically, S-E-A was requested to evaluate the alleged deficiencies in the work product of Casey Hawkins Glass, Inc. (Casey Hawkins), if the alleged deficiencies have resulted in damage to the buildings, and to evaluate proposed repairs related to the alleged deficiencies. Methodology The methodology utilized by S-E-A during the investigation of this incident was in accordance with The Scientific Method and applicable principles. The investigation and analysis of any incident is a complex and scientific endeavor. The methodology of such an endeavor, therefore, must include the comprehensive, objective, and accurate compilation and analysis of the available data. Conclusions The documents reviewed indicate there is not sufficient data, testing, and/or evaluations to substantiate the allegation that the alleged deficiencies at Villas at Emerald Lake are related to deficiencies in the work product of Casey Hawkins Glass, Inc., or that these alleged deficiencies have resulted in damage to the buildings. The documents reviewed indicate there is not sufficient data, testing, and/or evaluations to reasonably evaluate the scope of the SMH Construction Services estimated cost of repairs for Villas at Emerald Lake, or the extent to which these costs are associated with deficiencies in the work product of Casey Hawkins Glass, Inc. The data, testing, and analysis provided in the Marcon Report does not justify full removal and replacement of the windows installed by Casey Hawkins Glass, Inc. S-E-A Matter No. 04.116952 Silas Issue Date: November 1, 2021 4 of 30 Signatures S-E-A and the undersigned hereby certify the opinions and conclusions expressed herein were formed to a reasonable degree of professional certainty. They are based upon the application of reliable principles and scientific methodologies to all of the facts known by S-E-A and the undersigned when this report was issued, as well as knowledge, skill, experience, training and/or education. Should additional information be discovered, S-E-A and the undersigned reserve the right to appropriately amend or augment these findings. Prepared By: Technically Reviewed By: Robert M, Laralban / ju RichardWU. Meyorou | eu Robert M. Zaralban, P.E. Richard M. Meyerson Senior Civil/Structural Engineer State of Florida License No. 54106 SEA, LTD. CO 7001 Buffalo Parkway Columbus, Ohio 43229 COA No. 8430 S-E-A Matter No. 04.116952 Issue Date: November 1, 2021 5 of 30 Il. Procedures 1. S-E-A reviewed various documents, including the following: . filings relating to "Villas at Emerald Lake Homeowners Association, Inc. v. Royal Oak Homes, LLC, Weathermaster Building Products, Inc., et al. v. Casey Hawkins Glass, Inc., et al.", Case No. 2020-CA-002942, in the Circuit Court of the Ninth Judicial Circuit in and for Osceola County, Florida, including: . "Amended Complaint and Demand for Jury Trial", dated April 30, 2021 (Association's Amended Complaint); "Royal Oak Homes, LLC's Answer and Defenses to Plaintiff's Amended Complaint and Amended Crossclaim Complaint", dated May 20, 2021 (ROH Amended Crossclaim); "Weathermaster Building Products, Inc.'s Third-Party Complaint", dated January 18, 2021 (Weathermaster Third-Party Complaint); "Plaintiff's Expert Witness Disclosure", dated April 21, 2021 (Association's Expert Witness Disclosure); "Defendant/Crossclaim Plaintiff Royal Oak Homes, LLC's Designation of Experts", dated September 10, 2021 (ROH's Expert Witness Disclosure); "Defendant/Crossclaim Plaintiff Royal Oak Homes, LLC's Notice of Filing Expert Report", dated September 13, 2021; and "Defendant/Third-Party Plaintiff, Weathermaster Building Products, Inc.'s Notice of Filing Expert Witness Disclosure", dated October 1, 2021 (Weathermaster's Expert Witness Disclosure); "Weathermaster Building Products, Inc. Independent Contract Agreement" between Weathermaster Building Products, Inc. (Weathermaster) and Casey Hawkins, dated February 23, 2015; construction drawings for Lots 110 to 149 and 162 to 197 prepared for Royal Oak Homes by Brown + Company Architecture (BCA) (ROH Buildings); various Florida Product Approvals for windows manufactured by MI Windows and Doors (MI); S-E-A Matter No. 04.116952 Silas Issue Date: November 1, 2021 6 of 30 . documents prepared on behalf of Villas at Emerald Lake Homeowners Association, Inc. (Association), including: . documents prepared by Marcon Forensics (Marcon), including: . "Engineering Assessment Report", dated April 28, 2020; . "Engineering Assessment Report", dated April 2, 2021 (Marcon Report); "Villas at Emerald Lake, Non-Defect", dated June 15, 2021 (Marcon Defect Matrix); and . documents produced during discovery; . documents prepared by SMH Construction Services, Inc. (SMH), including: . "Villas at Emerald Lake, Preliminary Estimate - ROH Homes", dated April 5, 2021 (SMH ROH Estimate); and . documents produced during discovery; documents prepared by and on behalf of Weathermaster, including: . Villas at Emerald Lake Payment Records; . “Expert Report", prepared by RHBj Consulting, LLC (RHBj), dated September 29, 2021 (RHBj Report); and . documents produced during discovery; documents prepared on behalf of other parties, including: . "Evaluation Report", prepared by Alta Engineering Company (Alta), dated September 10, 2021 (Alta Report); and . "NVS5 Preliminary Expert Report", prepared by NV5, Inc. on behalf of Weintraub Inspections and Forensic, Inc., dated October 1, 2021; information obtained from the Osceola County Property Appraiser's (OCPA) website; aerial views of the community obtained from Google Maps and Bing Maps; portions of the following: . documents produced by American Architectural Manufacturer's Association, including: . AAMA 501.2-15, "Quality Assurance and Diagnostic Water Leakage Field Check of Installed Storefronts, Curtain Walls and Glazing Systems"; AAMA 502-12, "Voluntary Specification for Field Testing of Newly Installed Fenestration Products"; and S-E-A Matter No. 04.116952 Silas Issue Date: November 1, 2021 7 of 30 . AAMA 511-08, "Voluntary Guideline for Forensic Water Penetration Testing of Fenestration Products"; . documents produced by ASTM International, including: . ASTM E2128-17, "Standard Guide for Evaluating Water Leakage of Building Walls"; and various building codes, including: . Florida Building Code - Building, 2010 Edition (2010 FBC); . Florida Building Code - Residential, 2010 Edition (2010 FRC); . Florida Building Code - Building, 2014 Edition (2014 FBC); Florida Building Code - Residential, 2014 Edition (2014 FRC); and Florida Building Code - Existing Building, 7th Edition (2020). S-E-A Matter No. 04.116952 Silas Issue Date: November 1, 2021 8 of 30 II. Discussion Background Information Villas at Emerald Lake is a residential community consisting of twelve, two-story townhome buildings. Included as Figure 1 is an aerial view of the community from OCPA. Ten of the buildings were constructed by Royal Oak Homes, LLC (ROH) between 2015 and 2017. The two remaining buildings were constructed by The Damilola Group in 2008. The first-floor exterior walls of the ROH buildings are primarily constructed of concrete masonry unit (CMU) and finished with painted, direct-applied stucco. The second-floor exterior walls are constructed with wood frame and OSB sheathing and finished with painted stucco-over-lath. Based on the documents reviewed, ROH was the developer and general contractor for the ROH buildings. The construction plans for the ROH buildings were prepared by BCA. The ROH buildings were designed per the 2010 or 2014 Florida Building Code - Residential. ROH hired various subcontractors to construct the buildings including Weathermaster to supply and install windows. Weathermaster hired various subcontractors to install the windows, one of which was Casey Hawkins. Further discussion of Casey Hawkins' scope of work is addressed in the following section of this report. Based on the documents produced by Marcon, the windows are single-hung and mulled, single- hung Series GA 195, manufactured by MI Windows and Doors, LLC. S-E-A Matter No. 04.116952 Silas Issue Date: November 1, 2021 9 of 30 = = - a ms - *, . E - ue re ia 3 gli Figure 1: Aerial view of Villas at Emerald Lake (image obtained from OCPA). Review of Casey Hawkins' Scope of Work Included as Attachment 1 to this report is the contract between Weathermaster and Casey Hawkins which was included in Exhibit C of the Weathermaster Third-Party Complaint. A review of this contract indicates there was no specific scope of work defined for Casey Hawkins. Included as Attachment 2 to this report are Weathermaster's payment records which were included in Exhibit D of the Weathermaster Third-Party Complaint. Based on a review of the payment records, Casey Hawkins performed work on two, 8-unit buildings, specifically, the lots, as identified in Table 1. Aerial views of these buildings are included as Figure 2 and Figure 3 and identified in Figure 1. Of the sixteen units worked on by Casey Hawkins, five of those units (as S-E-A Matter No. 04.116952 icles Issue Date: November 1, 2021 10 of 30 identified in Table 1) had additional contractors involved in window installation. At the time of this report, the specific scope of work for each contractor in these units remains undetermined. Based on the payment records, the window installations performed by Casey Hawkins were invoiced on June 5, 2015 and May 27, 2016. The payment records do not identify any specific scope of work for Casey Hawkins. Casey Hawkins was not involved with the construction of The Damilola Group buildings. “Florida | Certificate Other Lot / : Address "Residential of ‘Subcontractors, Code Occupancy 12 2890 Tanzanite Terrace 2014 8/20/15 Well Done 143 2888 Tanzanite Terrace 2014 8/20/15 Well Done 144 2886 Tanzanite Terrace 2014 1/26/16 Well Done 145 2884 Tanzanite Terrace 2014 12/8/15 Well Done 146 2882 Tanzanite Terrace 2014 11/6/15 147 2880 Tanzanite Terrace 2014 12/9/15 148 2878 Tanzanite Terrace 2014 2/2/16 149 2876 Tanzanite Terrace 2014 8/28/15 182 2897 Sunstone Drive 2014 9/15/16 183 2899 Sunstone Drive 2014 9/19/16 184 2901 Sunstone Drive 2014 9/15/16 185 2903 Sunstone Drive 2014 9/15/16 186 2905 Sunstone Drive 2014 9/19/16 187 2907 Sunstone Drive 2014 9/21/16 Well Hung 188 2909 Sunstone Drive 2014 9/19/16 189 2911 Sunstone Drive 2014 9/19/16 Table 1: Building information for Casey Hawkins at Villas at Emerald Lake. S-E-A Matter No. 04.116952 Silas Issue Date: November 1, 2021 11 of 30 iea a m se ws: - o o teaies = “ fe -- . 2 :- - ee 8 a % . -. . + ~ oS eeee - =- e i . : a s = os - .a. . ee a. . . a os e oS ]. .o - ps - 2 .oe me oo. . , - - S| : < oo - /} - & ] oo S aS oo3 a S Ps : o ? 2 .2 7 e a . i i -. a = s a 2 a . ao s 2 Sy bi o < i - .. » = 7 ‘i ’ .ae oS a - oo Na ms Cae a. o oo aonyy i ‘igure 2: : Lots 142 to 149 (image obtained from OCPA) zs es zs ms = zs : = . 3 - . - oO -- - . - 2 s . - 2 co . = ] 2 s . . - -- o “ 7 2: D .- ee - 2 7 . . - - 3 S & -- 2 es . x — eo y . e os 2 2 - oe a o: A e=a. . a- ae 2 oe a 3 x - 2 S 3 o i . ae - co oSoS ae - ee aae. a a i 7 os _ - ee s . - es ree i ib - o =2a S ae _ pooa-. . a . = . a = a a es Be = = gure 3: Lots 182 to 189 (image obtained from OCPA). 4 S-E-A Matter No. 04.116952 icles Issue Date: November 1, 2021 12 of 30 Review of