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ConstructionRisk.com Report
http://www.ConstructionRisk.com
Vol. 12, No. 3, March 2010
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Inside
This Issue:
•
Construction Manager is Immune from a
Contractor’s Employee Personal Injury Suit pursuant to the Workers
Compensation Statute
•
Arizona
Supreme Court Reaffirms Economic Loss Doctrine;
•
Professional Services Providers Should not Agree to Defend Clients;
•
$26.9 Million in Liquidated Damages Not a Windfall to Power Plant Owner.
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NEW BOOK -- Risk Management for Design Professionals in a World of
Change,
J. Kent Holland, Esq., -- Editor
Chapters include:
-- Green Design and Construction
-- Integrated Project Delivery (IPD);
-- Building Information Modeling (BIM);
-- Public Private Partnerships (P3);
-- International Projects;
-- AIA Contract Documents;
-- ConsensusDOCS
-- EJCDC Documents
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Article
1
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Construction Manager is Immune from a
Contractor’s Employee Personal Injury Suit pursuant to the Workers
Compensation Statute
An individual who was employee of Company X, a firm that
contracted with the project owner to perform electrical work at a
construction site, fell from a forklift being operated by a project
superintendant employed by a Construction Manager (Company Y) who was
under separate contract to the project owner.
The CM hired an individual, Greg Beaver, employed by yet another
firm (Company Z) to
supervise the construction site, including the work performed by the
electrical contractor, and to make regular progress reports to the CM
firm. There was no written
contract between the CM and this superintendant, but they had an oral
contract and the CM paid the superintendent weekly -- but not as part of
payroll. Neither the
superintendant nor the CM had any contract with the electrical
contractor.
When
the electrician fell and was injured, he filed a personal injury suit
against Mr. Beaver, alleging that his negligence in operating the
forklift caused the laborer’s injuries.
Beaver moved for summary judgment on the basis that the CM for
whom he was working functioned as the general contractor on the site and
that he was merely acting as the CM’s employee or representative,
thereby entitling him to “up-the-ladder immunity.”
The trial court granted the summary judgment, agreeing that that
Mr. Beaver was the CM’s representative on the jobsite and as such was
immune from liability due to the workers compensation statute.
The summary judgment was reversed on appeal to the intermediate
appellate court, with the court finding that was no
contractor/subcontractor relationship existed between the electrical
contractor for whom the injured laborer worked and the CM or Mr. Beaver.
This was reversed by the Supreme Court of Kentucky –
reinstating the summary judgment in the case of Beaver
v. Oakley and Crawford Electric, 279 S.W.3d 527 (Kentucky 2009).
The key to the decision was whether Mr. Beaver was acting as a
“construction manager” rather than a “constructor” who
would be protected by the workers compensation act.
Under the law of the State of
Kentucky
an injured worker is not entitled to tort damages from his employer or
his employer’s employees for work related injuries.
Instead, the injured worker must rely exclusively upon workers
compensation. The term
“employer” is broadly construed under the state law to cover not
only the worker’s direct employer but also a contractor utilizing the
worker’s direct employer as a subcontractor.
The issue then for the court to decide was whether the evidence
established Mr. Beaver as a representative of the injured laborer’s
statutory employer such that Mr. Beaver would be entitled to
up-the-ladder immunity.
Factors that the court considered in deciding
that the CM firm and Mr. Beaver functioned as a “constructor” during
the construction phase of the project included the fact that they had
responsibilities of management, coordinating the work of various
parties, making sure that tasks were completed in accordance with plans
and specifications and actual day-to-day supervision of the construction
project. The court stated
that it recognized that a firm can function as the contractor on a
construction site “as a practical matter” despite “the lack of a
direct written contract between subcontractor and contractor.”
Based on deposition testimony the court stated the evidence
“demonstrates that [CM] actually functioned as the contractor and
Beaver as [CMs’] representative even though they may not have
established the type of written contract with [injured worker’s]
direct employer that was customarily expected in a
contractor-subcontractor relationship.”
The court found that the statutory language of the workers
compensation act “does not demand evidence of formal written contracts
between a defendant and the plaintiff’s direct employer for the
defendant to have up-the-ladder immunity but, rather, shows, that
contracts might be found in this context when the facts show that the
defendant is effectively functioning as a contractor.”
About the author: J. Kent Holland is a construction lawyer located in Tysons Corner,
Virginia, with a national practice (formerly with Wickwire Gavin,
P.C. and now with Construction Risk Counsel, PLLC) representing design
professionals, contractors and project owners. He is also founder
and president of ConstructionRisk, LLC, a consulting firm providing
consulting services to owners, design professionals, contractors and
attorneys on construction projects. He is publisher of
ConstructionRisk.com Report and may be reached at Kent@ConstructionRisk.com
or by calling 703-623-1932. This article is published in
ConstructionRisk.com Report, Vol. 12 No. 3 (March 2010).
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Article
2
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Arizona
Supreme Court Reaffirms Economic Loss Doctrine
P.
Douglas Folk, Esq. - Folk and
Associates, P.C.
I am very pleased to
report the Arizona Supreme Court’s favorable decision in the Flagstaff
Affordable Housing L.P. v. Design Alliance, Inc. case 2010 WL 476683
(Arizona, February 12, 2010). ACEC Arizona, AIA Arizona and ASFE joined
in filing an amicus curiae brief with the Supreme Court and we
participated in oral argument in this case before the Court.
The Supreme Court
has held design professionals may use the economic loss doctrine as a
legal defense in claims brought by their clients. The Supreme Court
decision went even farther than we thought it might, and it leaves no
uncertainty that a design professional’s client is limited to its
contract remedies when a design defect causes economic loss but no
physical injury to persons or other property. This ruling will enable
design professionals to negotiate with their clients over how much risk
they will assume, what compensation will be paid for assuming that risk,
and the remedies available to both parties in the event of a claim or
dispute.
In the
Flagstaff
case, the developer of an apartment complex sued its architect
for the cost of curing violations of the Americans with Disabilities Act
and Fair Housing Amendments Act. The developer claimed that the
architect and contractor’s violation of accessibility standards under
federal disability rights laws authorized the developer to sue for
damages under either contract or negligence law. The architect and
contractor obtained a dismissal of their respective contract or warranty
claims because they were barred by
Arizona
’s eight‐year statute of repose,
Ariz.Rev.Stat. § 12‐552.
The architect also convinced the trial court to dismiss the owner’s
professional negligence claim under the economic loss doctrine, because
the owner sought money damages unrelated to personal injury or property
damage. The Arizona Court of Appeals reversed this decision on appeal,
and held that the economic loss doctrine was not available to design
professionals. That ruling left the architect exposed to a tort claim
even though the client could no longer sue for a breach of contract.
The Arizona Supreme
Court has now vacated the Court of Appeals decision, holding that the
economic loss doctrine applies across the board in construction defect
cases. A property owner is “limited to its contractual remedies when
an architect’s negligent design causes economic loss but no physical
injury to persons or other property.” (We believe this rule protects
all design professionals or contractors, regardless of their
professional discipline or occupation.) The term “economic loss” is
defined in the decision to mean “pecuniary or commercial damage,
including any decreased value or repair costs for a product or property
that is itself the subject of a contract between the plaintiff and
defendant, and consequential damages such as lost profits.”
Reiterating another
recent decision upholding contractual limitations of liability, 1800
Ocotillo, LLC. v. The WLB Group, Inc., 219 Ariz. 200, 196 P.3d 222
(2008) (in which we also submitted an amicus curiae brief on
behalf of ACEC Arizona, AIA Arizona, the Arizona Professional Land
Surveyors Association and ASFE), the Supreme Court held that “in
construction defect cases involving only pecuniary losses related to the
building that is the subject of the parties’ contract, there are no
strong policy reasons to impose common law tort liability in addition to
contractual remedies.” To hold otherwise, the Court held, would
undermine the contract and upset the expectations of the contracting
parties.
Arizona
Supreme Court Re‐Affirms
Economic Loss Doctrine 2
The
Supreme Court’s decision in
Flagstaff
also includes these additional holdings that will be binding in
future cases against design professionals:
Arizona
’s
economic loss doctrine precedent in products liability cases, which
could allow tort claims in some cases considered “accidents”, is not
applicable to construction defect cases.
If a design professional’s client wants to preserve a tort remedy
in addition to its contract rights, it must write a contract that
explicitly says so. If the contract is silent on this point, the
presumption is that the economic loss doctrine will bar all tort claims
seeking only economic loss.
This rule does not bar a tort claim when economic loss is
accompanied by physical injury to persons or other property.
The rule in this case does not bar claims by third parties against
design professionals. If the substantive law allows liability in a
particular context—such as a contractor’s claim for negligent
misrepresentation based on defective plans and specifications—that
tort claim may be asserted by a third party. (As noted below, we believe
this issue will be addressed in a subsequent case for which review by
the Arizona Supreme Court has been requested.)
Violation of a legal duty imposed by statute, such as a building
code, does not override the economic loss doctrine; a client’s tort
claim will still be barred.
The design professional’s legally‐imposed duty of care also does not displace the general policy that
“parties to construction‐related
contracts should structure their relationships by prospectively
allocating the risks of loss and identifying remedies.”
There is no reason under
Arizona
law to distinguish design professionals from contractors (or anyone
else) for purposes of applying the economic loss doctrine.
It is likely that
the Arizona Supreme Court will accept review of another recent Court of
Appeals decision,
Hughes
Custom
Building
, LLC. v Davey, et al., 221 Ariz. 527, 212 P.3d 865 (App. 2009),
in which a third party sued a civil engineer with whom it did not have a
contract for economic loss damages when there was no personal injury or
damage to other property. That case, if it is reviewed, will allow the
Supreme Court to address how and when the economic loss doctrine will
apply to third party claims against design professionals. We hope to
file another amicus curiae brief in that case when it is heard by
the Court.
If you have any
other questions about this important new ruling, please contact me. This
is a great decision for design professionals and proof that much can be
accomplished when the design professions take an active role as amicus
curiae in key cases.
P.
Douglas Folk, Esq.
Folk & Associates, P.C.
3636 N. Central Avenue, Suite 600
Phoenix
,
AZ
85012
602-222-4400
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Article
3
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Professional
Services Providers Should not Agree to Defend Clients
J.
Kent Holland, Esq.
There
is no common law duty of a consultant to defend its client against third
party actions. That duty can
only arise as a result of a contractually liability created through the
indemnification clause of the contract.
Since this is a contractual liability, it is excluded from
coverage pursuant to the contractual liability exclusion of the errors
and omissions policy.
Courts
that have interpreted indemnification provisions that included the duty
to defend have explained that this means the consultant must defend its
client (pay legal fees on behalf of its client) as the litigation is
ongoing -- and that it cannot wait until the conclusion of the
litigation to determine whether it is found to have negligently
performed services and therefore owe a separate duty to indemnify.
The courts see the duty to defend and the duty to indemnify as
two separate and unique duties. The
insurance policy only covers damages to the extent they are caused by
the consultant's negligence - and that determination can only be reached
at the conclusion of the case or by settlement to which the carrier
agrees.
Although
it is theoretically possible that the damages awarded by a court might
include some attorneys fees if there is statute that requires the same,
attorneys fees are generally not awarded as part of a judgment in the
American system of justice. Therefore,
a clause stating that the consultant will defend (pay on behalf of) or
will indemnify (pay attorneys fees after judgment is rendered) both may
create uninsurable liability. Agreeing
to defend on behalf of a client, however, is the far worse situation
since the consultant would be paying out of its own pocket its client's
attorneys fees as they are incurred to defend against a third party
claim that might not even ultimately be found to have been caused by the
consultant's negligence.
My
routine advice for design professionals when reviewing their contracts
for insurability of risks:
“Please note that any duty to
defend its client that the design professional may agree to under an
indemnification clause, or other provision of the contract, is
uninsurable pursuant to the contractual liability provision of the
contract. Note also that it is our opinion that any duty to
defend should be struck from a contract, even if the contract states
that the duty to defend and indemnify is limited to damages resulting
from the negligent performance of professional services. This is
because we believe courts may interpret the duty to defend to be such a
broad separate duty from the duty to indemnify, that the consultant
could be expected to begin defending a claim on behalf of its client
(paying attorneys fees as they are incurred) as soon as a claim is
tendered by the client even if no determination of negligence has been
rendered.”
The
way I look at the issue is that a contractually agreed upon duty to
defend is triggered as soon as the claim is made because it is a
separate duty from the duty to indemnify. It is comparable to an
insurance company providing you a defense against a claim. It
doesn’t wait to see if you are negligent before defending you.
The carrier defends you in the hope of proving you are not negligent.
In my opinion, the clause below is
not a reasonable one for a design professional to sign because courts
may interpret the clause to mean that the indemnification requirement only applies to
damages ultimately caused by negligence – but that the defense
obligation is immediate and is not limited by the language of the clause
concerning negligence.
INDEMNIFICATION (example of problem clause)
The
Consultant covenants to save, defend, hold harmless, and indemnify the
County, and all of its elected and appointed officials, officers,
employees, agents, departments, agencies, boards, and commissions
(collectively the “County”) from and against any and all claims,
losses, damages, injuries, fines, penalties, costs (including court
costs and attorney’s fees), charges, liability, or exposure, however
caused, resulting from, arising out of, or in any way connected with the
Consultant’s negligent acts, errors, or omissions, recklessness or
intentionally wrongful conduct of the Consultant in performance or
nonperformance of its work called for by the Contract Documents.
This indemnification shall survive the termination of this Contract.
See,
for example, the recent California court decisions
of Crawford v. Weathershield Manufacturing, as well as the CH2M
Hill decision, that were reported in previous issues of this
newsletter.
Because of the confusing language in so many of the
contracts I am reading these days, I have suggested in some instances
adding the following paragraph to clarify the intent of the indemnity
obligations. It attempts to make clear that there will be no
defense duty, and that the indemnity is limited to costs and damages the
indemnitee is legally obligated to pay to third parties.
“Indemnification.
Notwithstanding any clause or provision in this Agreement or any other
applicable Agreement to the contrary, Consultant’s only obligation
with regard to indemnification shall be to indemnify and hold harmless
(but not defend) the Client, its officers, directors, employees and
agents from and against those damages and costs (including reasonable
attorneys fees and cost of defense) that Client is legally obligated to
pay as a result of the death or bodily injury to any person or the
destruction or damage to any property, to the extent caused by the
negligent act, error or omission of the Consultant or anyone for whom
the Consultant is legally responsible, subject to any limitations of
liability contained in this Agreement.
About the author: This article is written by
J. Kent Holland, a construction lawyer located in Tysons Corner,
Virginia, with a national practice (formerly with Wickwire Gavin,
P.C. and now with Construction Risk Counsel, PLLC) representing design
professionals, contractors and project owners. He is also founder
and president of ConstructionRisk, LLC, a consulting firm providing
consulting services to owners, design professionals, contractors and
attorneys on construction projects. He is publisher of
ConstructionRisk.com Report and may be reached at Kent@ConstructionRisk.com
or by calling 703-623-1932. This article is published in
ConstructionRisk.com Report, Vol. 12 No. 3 (March 2010).
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Article
4
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$26.9 Million in Liquidated Damages Not a Windfall to Power Plant Owner
By:
Judah
Lifschitz, Esq., --- Shapiro,
Lifschitz & Schram, P.C.
On
October 30, 2009, the DC Superior Court confirmed an August 17, 2009
arbitration award issued by a three-member arbitration panel in New
Athens Generating Co. et al. v. Bechtel Power Corp. et al.
The Panel awarded $26,950,000 in liquidated damages against the
construction giant Bechtel Power Corporation, EPC contractor of a $533
million power plant, after finding that it was responsible for over 200
days of delay and that the liquidated damages provisions of the EPC
contract were not a penalty and were enforceable as a matter of law.
The arbitration panel further found against Bechtel
on virtually all of its $94 million in claims against the project’s
owner, merchant power company, New Athens Generating Company,
LLC (“New Athens”).
The
decision in New Athens is particularly significant regarding the
enforceability of liquidated damages provisions.
Liquidated damages provisions are too frequently overlooked, but
can – and will – be enforced, often without consideration of actual
damages.
American
courts use two models to determine the reasonableness and enforceability
of a liquidated damages clause. Under
both, the clause is enforceable if the stipulated amount is found to
constitute reasonable compensation to the owner for inexcusable delay,
and unenforceable if the amount is found to constitute a penalty.
The two approaches differ as to whether the actual damages
suffered should have any bearing on the “compensation” versus
“penalty” determination. While
jurisdictions differ on the issue of how the reasonableness, and
consequently the enforceability, of a liquidated damages clause should
be determined, i.e., whether the liquidated damages clause should be
viewed solely as of the time of contracting, or with the benefit of
hindsight, the New Athens decision reflects on the former, as the
Panel found that the owner’s actual damages, calculated in hindsight,
were irrelevant to the determination of the reasonableness and
enforceability of the liquidated damages provision.
The
panel ruled that in order for the $149,000-a-day liquidated damages to
amount to constitute a penalty, “the quantum of damages proposed must
be shown to be unreasonable at
the time that the contract between the parties was negotiated.”
The fact that the amount may, with the benefit of hindsight, be
higher than the damages actually suffered is of no consequence.
The panel concluded that the evidence clearly established that
the amount stipulated by the parties in the EPC contract “was
reasonable at the time the contract was entered into.”
This
conclusion was based on both parties’ knowledge and sophistication
with respect to the economics of financing, construction and operating a
power plant, Bechtel’s previous experience working with New Athens’
parent company on “numerous other EPC projects,” and the fact that
both parties were represented by “competent and experienced
negotiators” at the time the EPC contract was entered into.
The
final award provides a clear and succinct statement of the law regarding
the enforceability of liquidated damages provisions.
Facts:
The
case involved a March 2001 Engineering Procurement and Construction
Contract between New Athens and Bechtel for the design, procurement and
construction of a $533 million 1080 megawatt power plant in upstate
New York
. Prior to entering into the
EPC contract with Bechtel, New Athens had issued a purchase order to
Siemens Westinghouse Power Corp. in April of 2000 for three 501G gas
turbines. New
Athens
subsequently assigned the Siemens contract to Bechtel in June of 2001,
after which Bechtel assumed responsibility for Siemens’ performance as
a subcontractor.
The
EPC contract required Bechtel to achieve substantial completion on
certain dates during July and August of 2003.
Bechtel, however, did not achieve substantial completion until
March 18, 2004, eight months behind schedule, triggering the contractual
liquidated damages of $149,000 a day.
At the end of the project, Bechtel claimed $94 million for the
outstanding contract balance of $26 million plus some $70 million in
alleged changes and compensable delays of over 200 days.
Central to Bechtel’s claims was its assertion that New Athens
had directed changes and improvements to the Siemens gas turbines,
thereby interfering with and delaying Bechtel’s work.
Siemens was a third-party respondent in the arbitration based on
New Athens’ claim for indemnification.
The Arbitration Proceedings:
The
arbitration proceedings were organized into three phases, sequenced to
address three major issues: (1) technology risk – did New Athens or
Bechtel bear the “technology risk” associated with Siemens’ new
501G gas turbines; (2) Force Majeure – was Bechtel entitled to its
claimed $9 million for an alleged Force Majeure event relating to
adverse winter weather; and (3) Project Delays/Liquidated Damages and
Other Related Issues including – (a) were product modifications issued
and implemented by Siemens during construction “betterments” for
which New Athens was liable, (b) who was responsible for the delays to
the project, (c) were $149,000/day in liquidated damages provided in the
EPC contract an illegal penalty, (d) was a 2004 settlement agreement
between New Athens and Bechtel setting the date for substantial
completion enforceable, and (e) was Siemens liable to New Athens for
indemnification.
Technology
Risk
Bechtel
and New Athens each claimed that the other bore the technology risk
associated with Siemens’ newly designed gas turbines, and thus was
responsible for the interferences and delays caused by design problems
and product modifications. Agreeing
with New Athens on virtually every point, the Panel ruled that Bechtel
had assumed the technology risk associated with the three 501G turbines
and the resulting impacts, and that Bechtel was therefore responsible
for project delays associated with the Siemens equipment.
Force
Majeure
The
Panel found that winter weather in 2002 constituted a Force Majeure
event, under the EPC contract. However,
with regard to Bechtel’s $9 million weather Force Majeure claim, it
rejected the vast majority of Bechtel’s claimed damages and awarded
Bechtel a mere $1 million out of the $9 million claimed.
Project
Delays
In
the final phase, the Panel ruled that the product
modifications issued and implemented by Siemens during
construction were necessary to achieve substantial completion, and not,
as Bechtel claimed, unnecessary enhancements or “betterments” for
which New Athens was liable. Since
Bechtel assumed the technology risk associated with the Siemens
equipment, the Panel denied Bechtel’s product modifications claims in
their entirety.
In
reaching its decision, the Panel held that Bechtel understood that the
project was intended to use three early 501G turbines which Siemens had
marketed without confirmation that the equipment would operate with
minimal need for further product modifications, and thus, Bechtel
assumed the risk that remedial product modifications might be necessary
to address problems with the immature Siemens technology.
The
Panel also rejected Bechtel’s claim that the $149,000 a day liquidated
damages provided for in the EPC contract were an illegal penalty.
The Panel held that under
New York
law, New Athens’ actual damages, calculated in hindsight, were
irrelevant to the determination of the provision’s enforceability.
Rather, in order to constitute a penalty, “the quantum of
damages proposed must be shown to be unreasonable at the time that
the contract between the parties was negotiated [and] [t]he fact
that the quantum may, with the benefit of hindsight, be higher than the
other party actually suffered is of no consequence.”
The Panel concluded that the evidence established that the amount
stipulated by the parties in the contract “was reasonable at the time
the contract was entered into.”
This
conclusion was based on, inter alia, the parties’ knowledge and
sophistication with respect to the economics of operating a power plant,
Bechtel’s previous experience working with New Athens’ parent
company on “numerous other EPC projects” and the fact that both
parties were represented by “competent and experienced negotiators”
at the time the EPC Contract was entered into.
The Panel also noted that Bechtel’s power plant economics
expert had failed to consider the reasonableness of the liquidated
damages amount as of the time of contracting, and, simply focused on the
reasonableness of the economics of New Athens operating the plant at the
time in 2003 and 2004. Instead,
the Panel accepted New Athens’ expert’s testimony because he had
“investigated the reasonableness of the quantum of liquidated damaged
at the time of contract formation.”
The
Panel also ruled that the 2004 settlement agreement between New Athens
and Bechtel, setting the date of substantial completion, was enforceable
and that Bechtel had failed to present any credible evidence that it was
misled into entering into the agreement.
Because the Panel rejected Bechtel's claims, Siemens was not
liable to New Athens for contribution or indemnity.
Award:
In
its final award, the Panel ruled that Bechtel had a contract balance of
$22.4 million, was owed $4.5 million for uncontested change orders, and
was entitled to $1.3 million for Force Majeure events.
The Panel awarded
Athens
$26.95 million in liquated damages due to Bechtel’s late completion of
the project. Thus, the net
amount which Bechtel was awarded was a mere $1.35 million as compared to
its claimed $94 million.
About the Author:
Judah
Lifschitz was lead counsel for New Athens Generating Co. LLC.
He is Co-President of Shapiro,
Lifschitz & Schram, P.C., (www.slslaw.com) a Martindale-Hubbell
AV-rated attorney and SuperLawyer. He
can be reached at lifschitz@slslaw.com
or 202.689.1900, ext. 3025.
=====================================
ABOUT THIS NEWSLETTER & A DISCLAIMER
About the author: All articles
in this issue of the ConstructionRisk.Com Report are written by
J. Kent Holland, a construction lawyer located in Tysons Corner,
Virginia, with a national practice (formerly with Wickwire Gavin,
P.C. and now with Construction Risk Counsel, PLLC) representing design
professionals, contractors and project owners. He is also founder
and president of ConstructionRisk, LLC, a consulting firm providing
consulting services to owners, design professionals, contractors and
attorneys on construction projects. He is publisher of
ConstructionRisk.com Report and may be reached at Kent@ConstructionRisk.com
or by calling 703-623-1932. This article is published in
ConstructionRisk.com Report, Vol. 12 No. 1 (January 2010).
This newsletter Report is published and edited by J. Kent Holland,
Jr., J.D. The Report is independent of any insurance company,
law firm, or other entity, and is distributed with the understanding
that ConstructionRisk.com, LLC, and the editor and writers, are not
hereby engaged in rendering legal services or the practice of law.
Further, the content and comments in this newsletter are provided for
educational purposes and for general distribution only, and cannot apply
to any single set of specific circumstances. If you have a legal issue
to which you believe this newsletter relates, we urge you to consult
your own legal counsel. ConstructionRisk.com, LLC, and its writers and
editors, expressly disclaim any responsibility for damages arising from
the use, application, or reliance upon the information contained herein.
Copyright 2010, ConstructionRisk, LLC
Publisher & Editor:
J. Kent Holland,
Jr., Esq.
1950
Old Gallows Rd
Suite 750.
Vienna
,
VA
22182
703-623-1932
Kent@ConstructionRisk.com
_____________________________________________
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