Motion-Secondary: Jibo & Company, Inc. vs. Duddy, Ryan A et al

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                                CERTIFICATE OF SERVICE

        I, Stephen P Griffin, do hereby certify that on the 23rd day of April, 2021, I served a copy
of the foregoing document to counsel of record by e-mail.

                                                                 Mh
                                                              Stephen P. Griffin
#15
                                                                                      FILED 4/23/2021
                              COMMONWEALTH OF MASSACHUSETTS

      NANTUCKET, ss.                                               SUPERIOR COURT DEPT.
                                                                   OF THE TRIAL COURT
                                                                   Civil Action No. 1975CV00002

      JIBO & COMPANY, INC.,
                      Plaintiff

               Vv.


      RYAN A, DUDDY and ERICA D.
      DUDDY,
                      Defendants

                      DEFENDANTS’ AMENDMENT TO JOINT PRE-TRIAL
                               MEMORANDUM SECTION IX

           Now come the Defendants and hereby submit the following amendment to Section IX of

  the Joint Pre-Trial Memorandum filed with the Court on March 10, 2021.

           x         DEFENDANTS’ EXPERT WITNESSES

           Defendant Ryan Duddy (“Duddy”) expects to call Christopher Skehel as a rebuttal expert

  witness at the trial of this action. Mr. Skehel is expected to testify as to the fair and reasonable

  value of the material and labor supplied to Duddy by the Plaintiff as well as the quantity of

  materials required to complete the roofing and sidewall portions of the subject property.

           In particular, Mr. Skehel is expected to testify that the fair and reasonable value of the

  labor and materials supplied by the Plaintiff was $57,850, which includes a profit of $21,430, for

  a fair value, excluding profit of $36,420. Mr. Skehel is also expected to testify that the charges

  set forth on Jibo & Company Invoice #221 greatly exceed the fair, reasonable and customary

  charges for the amount of roofing and sidewall work completed by Jibo. In addition, it is

  expected that Mr. Skehel will testify that certain of the materials reflected on Jibo Company
Invoice #221 and Shepley invoices, bates labeled Duddy 12 - Duddy 17, substantially exceed the

amounts required for a project of this size.

        Mr. Skehel’s opinion is based upon his extensive experience as a residential builder and

general contractor on Nantucket, as well as his inspection of the subject property, review of the

plans labelled “New Dwelling - Duddy; 1 Monohansett, Nantucket, MA; Brooks Meerbergen

design; Dated 9/18/17, Pages 1, 2, 3, 4, cl, c2 and c3,” and review of the documents produced by

the parties in this litigation.

        Mr. Skehel’s opinion will be based upon his extensive experience with the labor and

material costs on Nantucket and the industry standards related to the contracting and appropriate

billing for labor and materials in the roofing and siding profession on Nantucket.

        Mr. Skehel holds Massachusetts Construction Supervisor License No. CS-091597.



                                                      Respectfully submitted,

                                                      RYAN A, DUDDY and ERICA D. DUDDY

                                                      By their attorneys,

                                                      GRIFFIN LAW LLC


                                                         lohfl—
                                                      Stephen   P. Griffin (BBO# 563369)
                                                     224 Clarendon Street, Suite 32
                                                     Boston, MA 02116
                                                     (617) 266-9600 (phone)
                                                      pe@seriffinlaw.com